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Nowhere to Hide: Modelo 720 and Common Reporting Standards

The implications of these two pieces of legislation on the financial planning of expatriates cannot be ignored. In short, it means that the concept of ‘offshore’ with regards to banking and asset holding is now a thing of the past.

The CRS, which was created by the Organisation for Economic Cooperation and Development (OECD), relates to the automatic exchange of information from Reportable Accounts between the jurisdictions that have signed up to the scheme. In regards to what is considered a Reportable Account, the OECD hasn’t outlined specific criteria and instead have left it up to each jurisdiction to determine what qualifies as a Reportable Account.

The CRS was implemented within the EU on the 1st January 2016, and ultimately created with the intention of eliminating any and all places for those attempting to avoid their tax obligations, thereby forcing them to become compliant with the necessary tax regulations sooner rather than later. The information to be exchanged with the CRS, therefore, would be anything which could be of interest to a tax authority keen to identify whether or not a person is committing tax evasion.

The CRS is of particular interest to any expats living in Spain and that have failed to submit a Modelo 720 (the foreign asset declaration). The old justification for not submitting a Modelo 720 – because Hacienda were unlikely to find out about assets held outside of Spain – can no longer be said to hold much truth anymore, mainly because Hacienda should now already be automatically informed of that information. 

With all of this being the case, it has never been more important to seek professional financial advice. The consequences of not complying with the latest tax legislation could be dire. Ensuring that your financial affairs are all set up in a tax efficient manner and, more importantly, in a legally compliant manner, could not only save you a huge headache, but also save you from a potentially crippling tax bill.

This communication is for informational purposes only and is not intended to constitute, and should not be construed as, investment advice, investment recommendations or investment research. You should seek advice from a professional adviser before embarking on any financial planning activity. Whilst every effort has been made to ensure the information contained in this communication is correct, we are not responsible for any errors or omissions.

Other News

The Pensions Black Hole

Meeting financial advisorThere’s quite a buzz around pensions at the moment – and rightly so, as they provide the backbone of our income in our later years. But currently, pension deficits are hitting the news, and figuring them out can still prove difficult.

Pension deficits concern what are commonly known as “final salary pensions” or Defined Benefit schemes.   Final salary or defined benefit (DB) schemes are essentially occupational pension schemes that provide a set level of pension at retirement, the amount of which normally depends on your service and earnings at retirement or in the years immediately preceding when you retire. Because your pensionable salary is used as one part of the formula in order to calculate your pension, a final salary scheme is commonly referred to as a ‘salary related’ scheme. Two common examples of ‘final pensionable salary’ would be your last year’s pensionable earnings or an average of your last 3 years’ pensionable salary.

Recently, there have been high-profile failures of these systems, such as the folding of Monarch Airlines – and the collapse of their pension fund. Initially, it appeared that owners could still walk away with a profit (after new hands tried to turn the airline into a more accessible and “Ryanair-like” product) by offloading debts, and this included dropping the pension fund. Ironically, this was once a major credit to the business. The fund, which is now in the Pension Protection Fund (PPF), had been under speculation of being left short when the business first began to struggle back in 2014, after years of asset-stripping.

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Alternatives for Savers?

Blacktower Alternative SavingsYour cash is earning nothing in the bank, in fact it’s actually losing its worth in all probability because of the corrosive effect of inflation.  Even ostriches have to raise their heads at some point, if only to breathe.

Quite frankly it’s time for people to start taking control of their money instead of letting the banks bleed them.  In the days we are in now with increased life expectancy, a longer wait for retirement and the pension freedoms that there are around, there could not be a better time for savers to act and improve their lot.  So you go to see a financial adviser, what is he going to say?

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