Explanatory Note – CRS Deactivations

Summary

This is DITC guidance explaining what supporting documentation Reporting Financial Institutions (FIs) and Trustee Documented Trusts (TDTs) must submit to the DITC Portal when requesting a CRS 'deactivation' — that is, when an entity is being removed from the CRS reporting system because it has terminated (dissolved, struck off, or had a segregated portfolio/sub-fund wound up) or because its CRS classification has changed from a Financial Institution to an Active or Passive Non-Financial Entity (NFE). It supplements the DITC CRS Guidelines and Portal User Guide by clarifying the mechanics of the final return and listing, on a non-exhaustive basis, the types of evidence expected for each deactivation scenario.

Before a deactivation request is submitted, the entity must have completed all outstanding CRS reporting for every year it was registered on the Portal up to the date on its Certificate of Dissolution (or equivalent), including a CRS Return, CRS Filing Declaration, and, for 2019 onward, a CRS Compliance Form. The Principal Point of Contact (PPoC) then submits the deactivation request itself along with consolidated documentary evidence, and only one file may be uploaded.

Termination-based deactivations

• Corporations and SPCs: Strike-off/dissolution certificates are required, plus a list of underlying segregated portfolios for SPCs.
• Trusts: A signed trust deed or trustee resolution terminating the trust is required, plus a list of sub-entities for unit trusts.
• Partial SP/sub-fund terminations: A signed board/trustee resolution is required.
• Partnerships: Strike-off/dissolution certificates are required.

Classification-change deactivations

Where an FI is reclassified as an Active or Passive NFE, a detailed letter is required explaining the original and new classification and the CRS basis for the change.

• Supporting evidence may include: non-consolidated financial statements; management accounts or trial balances demonstrating passive income/asset thresholds; confirmation of who manages the entity's assets; or, for Investment Entities failing the gross income test, three years of financial data.

Key obligations

• Before submitting a deactivation request, the Reporting FI or TDT must complete all outstanding CRS reporting obligations for every year it was registered on the Portal up to the date on its Certificate of Dissolution (or equivalent).
• The FI must submit a final CRS Return, CRS Filing Declaration, and (for 2019 reporting period onward) a CRS Compliance Form covering the final reporting period.
• The final CRS Return's 'End Date' must be 31/12 of the year the FI terminated, regardless of when during the calendar year it is actually filed.
• The final return must include all information specified in Section I.A.1 to 7 of Schedule 1 to the CRS Regulations for any Reportable Account, confirming account closure and the total gross amount of relevant payments or proceeds of sale.
• The PPoC must submit the FI Deactivation Request via the DITC Portal and upload the required documentary evidence, consolidated into a single file since only one upload is permitted.
• For termination-based deactivations, the entity must provide the applicable evidence (e.g., strike-off/dissolution certificates, trust deed/resolution of termination, list of underlying SPs or sub-entities, or board/trustee resolutions for partial SP/sub-fund terminations).
• For classification-change deactivations, the entity must submit a letter explaining the basis for reclassification (from FI to Active or Passive NFE) and supporting documentation such as financial statements, management accounts, or trial balances demonstrating the relevant income/asset thresholds or management arrangements.

Applies to

Reporting Financial Institutions, Trustee Documented Trusts (TDTs), Corporations, Segregated Portfolio Companies (SPCs), Trusts, Unit Trusts, Partnerships, Investment Entities, Passive NFEs, Active NFEs

Deadlines

• 31/12 of the year the FI terminated: The 'End Date' of the final CRS Return submitted for deactivation must be set to 31 December of the year the FI terminated, even if filed later in the following year.