IGOR-FATCA Schema for UK IGA reporting

About this document

This document describes the XML schema which will be used for UK IGA reporting via IGOR.

Why is a new schema required?

The XML schema for UK IGA reporting will be 'IGOR-FATCA'. This is almost identical to the IRS FATCA XML schema v1.1, but it has been necessary to extend the IRS schema slightly in order to cope with the requirements of ARR. In particular:

IGOR-FATCA is a superset of IRS FATCA, which means that any valid IRS FATCA XML message can be trivially transformed to a valid IGOR-FATCA XML message just by changing the XML namespaces. This should mean that existing code for generating messages for US FATCA reporting can be reused to generate XML for the UK IGA in the IGOR-FATCA format with minimal alteration.

All FIs reporting under the UK IGA must use the IGOR-FATCA schema. However, for FIs which are not offering ARR, the reporting format and semantics are identical to the IRS FATCA schema apart from the change of XML namespaces.

Most of the information in this document therefore refers to extensions which are required to support the ARR, and is only relevant to FIs offering ARR.

Please note that IGOR-FATCA is named after FATCA only because it is derived from the IRS schema for FATCA reporting. At this stage it is only intended to be used for reporting under the UK IGA, and cannot be used for US FATCA reporting. FIs must continue to use the IRS FATCA schema for reporting under US FATCA.

Feedback

Please address any queries or feedback on this document to the IGOR Forum.

Version history

Registration and authentication

Financial institutions which have already been authorised for another reporting type do not require further authorisation to submit reports for the UK IGA. The UK reporting types can be added after logging into IGOR and used immediately.

New registrations for reporting under the UK IGA can be made using either the US GIIN, or simply the name of the FI. For FIs registered without a GIIN, the FI name in the report XML must exactly match the registered name, including letter case.

To allow submission of reports for organisations which contain only FIs registered without a GIIN, the SendingCompanyIN in the MessageSpec element may now be either a valid GIIN which is one of the Organisation's authorised FIs, or the IGOR organisation ID. This applies to all reporting types, and use of the IGOR organisation ID is recommended for all reporting types.

IGOR-FATCA schema XSD files

The IGOR-FATCA schema XSD files can be downloaded here as a ZIP archive:

The archive contains five component XSD files, which are all required to describe the schema. Four of these correspond to equivalent files from the IRS FATCA XML schema. There is also an IGORTypes.xsd file which describes the form of the new optional 'Period' element for AccountReports.

Reporting phases for Standard and ARR UK IGA reporting

The IGOR-FATCA schema supports three new MessageType codes UK_STANDARD, UK_ARR_BASIC and UK_ARR_FULL which correspond to three phases of returns under the UK IGA.

FIs will be able to register separately for Standard and ARR reporting.

Standard (non-ARR) reporting

A standard return will be required each year from all FIs which are registered for standard UK IGA reporting by 30 June. The ReportingPeriod date for a standard return will be 31 December at the end of the calendar year being reported. The format of a standard reporting is the same as a US FATCA report, but using the IGOR-FATCA namespaces (see the Namespaces section below) and the UK_STANDARD MessageType.

Alternate Reporting Regime

Any FI which registers with IGOR to offer the Alternate Reporting Regime for UK taxable Period 15/16 (year ended 5 April 2016) will be required to submit an 'ARR Basic' return of basic account information, as required by the regime, by 30 June 2016. The ReportingPeriod date for that report will be 5 April 2016. The report should contain the required BASIC ARR information of account holders who have completed election for ARR for the UK tax year ending 5 April 2016 by 30 May 2016. Failure to meet the election deadline precludes the account holder from ARR reporting, and the STANDARD report should be made. If the FI has registered with IGOR to indicate it is offering ARR, but no account holders complete election, the FI will be required to submit a nil ARR Basic return.

By 30 June 2017, FIs offering ARR will be required to submit an 'ARR Full' return of full account information with a ReportingPeriod of 5 April 2016, containing account holders who have completed self-certification by 28 February 2017. From then on, both an ARR Basic and an ARR Full return will be required each year by 30 June. Failure to meet the election deadline precludes the account holder from ARR reporting, and the STANDARD report should be made.

Because of the delay in reporting of ARR accounts for the UK Tax Year 14/15 (year ended 5 April 2015), and the duplication of information required between BASIC and FULL ARR returns, for UK tax year 14/15 only a FULL ARR return is required. The ReportingPeriod date for that report will be 5 April 2015. If there were no reportable movements of assets or gross payments, then only the BASIC information is required and these amounts may be reported as �0�.

Reporting part-years

Because the reporting periods for ARR and Standard reporting are different, it may be necessary in rare circumstances to submit part-year reports for some accounts in the event that an account holder enters or leaves ARR.

In order to cater for this, the IGOR-FATCA schema offers a new optional Period element within the AccountReport element. If specified, this can be used to indicate that the payments listed for that AccountReport refer only to part of the year indicated in the ReportingPeriod element.

See the section on the Period element below for an XML example of this.

Supplementary reports

In some cases it may be necessary to make supplementary reports for a given year. For example an account holder may choose reporting under ARR, which is reported in the ARR Basic return for the year ending 5 April 2016, but they may fail to complete self-certification in time for returning an ARR Full return in 2017.

In that case the FI will be required submit a supplementary standard return for the year ending 31 December 2015 containing the details for that account. Such supplementary reports should be submitted to IGOR in the normal way. In general, any number of further returns can be made for the same reporting period as required. These are simply added to the data already returned.

Differences between IGOR-FATCA and IRS FATCA

This section lists the differences which have been introduced in this schema in order to cater for UK ARR reporting. These differences are illustrated with examples to show how the new elements are intended to be used for IGOR.

Namespaces

The IGOR-FATCA schema introduces three new namespaces in order to allow for the IGOR alterations to elements of the IRS FATCA schema. The header of an IGOR-FATCA XML message should look like this:

<?xml version="1.0" encoding="utf-8"?>
<ftc:FATCA_OECD
  xmlns:ftc="https://igor.gov.gg/Schemas/IGORFatcaXML/v1"
  xmlns:iso="urn:oecd:ties:isofatcatypes:v1"
  xmlns:sfa="https://igor.gov.gg/Schemas/IGORstffatcatypes/v1"
  xmlns:igor="https://igor.gov.gg/Schemas/IGORTypes/v1"
  version="1.1">

New message types

In order to distinguish which phase of reporting under the UK IGA a message is intended for, three new values for the MessageType element have been added:

The MessageType code FATCA (defined by the IRS FATCA schema) must not be used for UK IGA reporting.

New account holder types

Two new account holder types have been added to allow reporting under the UK IGA.

As an alternative to the above, the following existing US specific entries may be used, but will be taken to relate to the equivalent in the UK:

The account holder types FATCA101, FATCA103 and FATCA105 must not be used for UK reporting.

New payment types for ARR payments/movements

The ARR requires gross payments to be reported under four payment types which do not correspond to the four payment types of FATCA reporting.

IGOR-FATCA therefore defines four new codes corresponding to these different payment types:

The IRS FATCA codes FATCA501-FATCA504 must not be used for ARR reporting.

The use of these payment types is illustrated in this sample:

<ftc:AccountReport>
  <ftc:DocSpec>...</ftc:DocSpec>
  <ftc:AccountNumber>1234</ftc:AccountNumber>
  <ftc:AccountHolder>
    <ftc:Individual>...</ftc:Individual>
  </ftc:AccountHolder>
  
  <ftc:Payment>
    <ftc:Type>IGOR501</ftc:Type> <!-- gross payments from UK source -->
    <ftc:PaymentAmnt currCode="GBP">35000.00</ftc:PaymentAmnt>
  </ftc:Payment>
  <ftc:Payment>
    <ftc:Type>IGOR502</ftc:Type> <!-- gross payments from unknown source territory -->
    <ftc:PaymentAmnt currCode="GBP">7434.00</ftc:PaymentAmnt>
  </ftc:Payment>
  <ftc:Payment>
    <ftc:Type>IGOR503</ftc:Type> <!-- gross payments to UK destination -->
    <ftc:PaymentAmnt currCode="GBP">15000.00</ftc:PaymentAmnt>
  </ftc:Payment>
  <ftc:Payment>
    <ftc:Type>IGOR504</ftc:Type> <!-- gross payments to unknown destination territory -->
    <ftc:PaymentAmnt currCode="GBP">0.00</ftc:PaymentAmnt>
  </ftc:Payment>

</ftc:AccountReport>

AccountBalance is optional

The AccountBalance is never reportable under ARR, so in IGOR-FATCA this element is optional within an AccountReport. The above snippet contains no AccountBalance element and is valid IGOR-FATCA.

AccountNumber is optional

The AccountNumber is not reported in ARR Basic returns, so it has been made optional in IGOR-FATCA. A missing AccountNumber element indicates that the account number is not being reported. Note this is distinct from the US FATCA convention of reporting an account number of NANUM, which means that the account does not have a number.

New Period element

In the rare circumstances that it is necessary to indicate that the payments in an AccountReport refer to a part-year, a new optional Period element has been added:

<ftc:AccountReport>
  <ftc:DocSpec>...</ftc:DocSpec>
  <ftc:AccountNumber>1234</ftc:AccountNumber>
  <ftc:AccountHolder>...</ftc:AccountHolder>
  
  <ftc:Period>
    <igor:Start>2015-01-01</igor:Start>
    <igor:End>2015-04-05</igor:End>
  </ftc:Period>
  
  <ftc:Payment>...</ftc:Payment>
  ...
</ftc:AccountReport>

The above XML includes a Period element indicating that the payments in the AccountReport refer only to the period from 2015-01-01 to 2015-04-05.

The period dates must fall within the year ending on the return's ReportingPeriod date, and must be one of the following:

If the Period element is not included, it is assumed that the information in the AccountReport refers to the full year ending on the date given in the ReportingPeriod element.