How to Complete the Entity Self-Certification Form for CRS and FATCA

The entity self-certification form for CRS and FATCA asks you to do four things: identify the entity, classify it, list every country where it is tax resident along with the tax identification number for each, and — if the entity is Passive — name its controlling persons. A signed declaration at the bottom binds the entity to the accuracy of what you wrote and to updating the bank when things change. The form follows an OECD template, so the fields below appear on almost every bank’s version even if the layout differs.1OECD. Entity Tax Residency Self-Certification Form

Part 1: Entity Identification

The first block is straightforward but must match your formation documents exactly. Have these ready:

  • Legal name as it appears on the certificate of incorporation or formation. Not a trade name or DBA.
  • Country of incorporation or organization.
  • Current residence address — the physical street address of the principal office. A P.O. box alone will not satisfy this field.
  • Mailing address, if different from the residence address.

These are mandatory on the OECD standard form, and bank versions track them closely.1OECD. Entity Tax Residency Self-Certification Form Mismatches with the account application (a different address, a slightly different legal name) trigger follow-up from the bank’s compliance team, so cross-check before signing.

Part 2: Classifying the Entity

This is the section that determines everything else on the form. Get it wrong and you either trigger unnecessary reporting about the people behind the entity or you flag the account incorrectly. The form splits entities into Financial Institutions and Non-Financial Entities, and then splits NFEs into Active and Passive.

Financial Institution

Your entity is a Financial Institution under CRS if it fits one of four categories:

  • Depository Institution — accepts deposits as a regular part of a banking or similar business.
  • Custodial Institution — holds financial assets for others as a substantial part of its business.
  • Investment Entity — gross income comes primarily from investing, reinvesting, or trading financial assets, or the entity is managed by another Financial Institution engaged in those activities.
  • Specified Insurance Company — an insurance company (or its holding company) that issues or must make payments on cash-value insurance or annuity contracts.

If you check Financial Institution, the form asks for the Global Intermediary Identification Number, a code assigned through the IRS FATCA registration system.2Internal Revenue Service. FATCA Registration and FFI List – GIIN Composition Information Not every FI has one; the form says to provide it “if held.”

One edge case catches people out. An Investment Entity located in a jurisdiction that has not adopted CRS, and managed by another Financial Institution, is treated as a Passive NFE for reporting purposes even though it is technically an FI.1OECD. Entity Tax Residency Self-Certification Form If that describes your entity, you complete the controlling persons section as a Passive NFE would.

Active Non-Financial Entity

If the entity is not a Financial Institution, the next question is Active or Passive. The distinction matters because Passive NFEs must disclose the individuals who control them. Most operating businesses are Active. The OECD form lists these qualifying categories:1OECD. Entity Tax Residency Self-Certification Form

  • Publicly traded corporation, or a related entity of one. You will need to name the market on which the stock is regularly traded.
  • Government entity or central bank.
  • International organization.
  • Other Active NFE — the catch-all covering start-ups, non-profits, and any entity where less than 50 percent of the prior year’s gross income was passive and less than 50 percent of assets produced or were held to produce passive income.3Australian Taxation Office. 8 Glossary

The 50 percent income test is where most companies land. Passive income for this test includes dividends, interest, annuities, royalties, rents, and capital gains from selling non-inventory assets. A manufacturer, consulting firm, or retailer whose revenue comes from operations almost certainly qualifies as Active.

Passive Non-Financial Entity

An entity that doesn’t meet any Active NFE category is Passive by default.3Australian Taxation Office. 8 Glossary Typical examples are a holding company living off dividends from a stock portfolio, or a family investment vehicle earning rental income and capital gains. Checking this box means the controlling persons section applies to you.

Controlling Persons

For a Passive NFE — or the Investment Entity edge case described above — you must identify every controlling person. For a company, that is any individual who directly or indirectly holds more than 25 percent of the shares or voting rights. If no one meets that threshold, the controlling persons are the individuals who exercise control through management, such as a senior managing official.3Australian Taxation Office. 8 Glossary

The entity form itself only asks for each controlling person’s name. Each of those people must then complete a separate Controlling Person Tax Residency Self-Certification Form, which collects their personal tax residency, address, date of birth, and TIN.1OECD. Entity Tax Residency Self-Certification Form Coordinate with them before you submit. Banks generally will not process the entity certification without the companion forms.

Part 3: Tax Residency and TIN

Part 3 is a table. List every country in which the entity is tax resident and the taxpayer identification number issued by that country. For a U.S. entity, the TIN is usually the Employer Identification Number.4Internal Revenue Service. Employer Identification Number If no TIN is available for a jurisdiction, pick one of three standard reasons:

  • Reason A — the country does not issue TINs to its residents.
  • Reason B — you are otherwise unable to obtain a TIN, and you must explain why.
  • Reason C — no TIN is required, available only where the jurisdiction’s domestic law does not require the TIN to be collected.1OECD. Entity Tax Residency Self-Certification Form

Figuring Out Where the Entity Is Tax Resident

Entity tax residency usually turns on where the entity was incorporated or where its central management and control sits. A company incorporated in the U.S. and run from a U.S. office lists only the United States. It gets harder when the entity is incorporated in one country and its directors make key decisions from another. Some jurisdictions look at the place of incorporation; others focus on where senior management operates day to day.

If the entity qualifies as resident in two countries at once, treaties between those countries often include tie-breaker rules — where the board regularly meets, where the registered office sits, and similar factors. Where dual residency is a genuine possibility, a cross-border tax advisor can help you decide which jurisdictions to list. This is not just a form problem; the answer determines which country’s tax authority receives your data through automatic exchange.

Signing the Declaration

The signature block carries real weight. By signing, you certify that the information is correct and complete to the best of your knowledge, and you commit to telling the financial institution when a change in circumstances makes anything on the form inaccurate.1OECD. Entity Tax Residency Self-Certification Form You also acknowledge that the information may be reported to tax authorities and exchanged with other countries under intergovernmental agreements.

The signer must be someone authorized to act on behalf of the entity for the accounts the form covers. Print your name, indicate your capacity (Director, Authorized Officer, and so on), and date the form. If you’re signing under a power of attorney, attach a certified copy.

Keeping the Form Current

The obligation continues after submission. Notify the bank whenever something changes that affects the entity’s tax status or the accuracy of the form. Common triggers: moving the entity’s headquarters to a different country, restructuring in a way that shifts its classification, or a change in the controlling persons of a Passive NFE.

The OECD template leaves the update deadline blank, and each jurisdiction and institution fills it in. In practice, some jurisdictions allow up to 90 calendar days from the date the original certification became invalid before the bank must treat the account as undocumented.5GOV.UK. New Individual Accounts – Self Certifications – Change of Circumstances Your bank’s version will state its exact window. Update promptly rather than pushing the deadline; a late update risks the account being flagged or restricted while compliance sorts it out.

If You Don’t Submit or the Form Is Incomplete

Two things happen. Under FATCA, U.S. financial institutions are required to withhold 30 percent of certain U.S.-source payments made to foreign entities they cannot properly document.6Internal Revenue Service. FATCA Information for U.S. Financial Institutions and Entities Those payments include dividends, interest, and other fixed or determinable U.S.-source income. Reclaiming withheld amounts later means filing for a refund, which is slow.

On the CRS side, the pressure is institutional. A bank that cannot document an account holder’s tax status faces its own compliance exposure, and most respond by restricting or closing the account. That closure isn’t an enforcement action against your entity; it is the bank protecting itself. The end result is the same either way: no banking services until the documentation is in.

How This Form Differs From the IRS W-Forms

The CRS self-certification is not an IRS form and does not replace one. A U.S. entity opening an account at a foreign institution may need to complete both the CRS form and IRS Form W-9, which supplies the Taxpayer Identification Number for U.S. reporting.7Internal Revenue Service. Request for Taxpayer Identification Number and Certification Foreign entities receiving U.S.-source income use Form W-8BEN-E to document beneficial-owner status and claim any treaty-based reduced withholding rate.8Internal Revenue Service. About Form W-8 BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting Foreign intermediaries and flow-through entities use Form W-8IMY. The CRS form feeds the OECD’s multilateral reporting network, which runs alongside the FATCA system rather than as part of it, so a single account opening can require both a CRS certification and a W-form depending on the jurisdictions involved.