CRS Self-Certification FAQs for Companies: Tax Residency & TINs

Financial institutions collect information about where account holders are tax resident and how their organisations should be classified for international tax reporting. For companies, this often involves completing a CRS self-certification.

These frequently asked questions explain the terminology, the information a company may be asked to provide and why those details need to remain accurate. The final section covers the UK changes applying from the 2026 reporting year and the associated reporting deadline.

Understanding CRS self-certification

What are AEOI, CRS and FATCA?

Financial institutions may collect information relevant to both CRS and FATCA through the same form. Each framework has its own classification and reporting requirements.

What is a CRS self-certification?

A CRS self-certification is a declaration through which an account holder confirms its tax residence and relevant status under the Common Reporting Standard.

For a company, the declaration is signed or otherwise positively affirmed by someone authorised to act on its behalf.

Why do financial institutions need this information?

Tax residence, Tax Identification Numbers and entity classification help financial institutions determine whether an account is reportable and which information must be reported under the applicable rules.

Self-certifications form part of the due diligence used to establish that position. Financial institutions also assess whether the declaration is reasonable alongside other customer information they hold.

What information is usually included in a corporate self-certification?

Depending on the entity and circumstances, the information may include:

• the legal entity name and address;
• all relevant jurisdictions of tax residence and the corresponding TINs, where required;
• the entity’s CRS classification;
• details of relevant Controlling Persons, where applicable; and
• the authorised representative’s name and capacity, signature or positive affirmation, and the date of the declaration.

Who can complete the self-certification?

Someone with authority to act for the organisation must sign or positively affirm the declaration.

HMRC gives examples including a company officer or director, a partner of a partnership, a trustee of a trust or another appropriately authorised person.

What makes a self-certification valid?

A self-certification needs to contain the information required for the relevant account and be signed or positively affirmed by an authorised person. The financial institution must also assess its reasonableness against other information held.

For a New Account, HMRC states that a self-certification must contain a TIN for each reportable jurisdiction that issues one in order to be valid. Requirements can differ for Pre-existing Accounts.

Tax residence and Tax Identification Numbers

What is a Tax Identification Number?

A Tax Identification Number, or TIN, is an identifier used by a tax administration to identify an individual or entity for the administration of its tax laws.

Names and formats vary between jurisdictions. Some jurisdictions use another identifier that performs an equivalent function.

Is a TIN the same as a VAT number?

A TIN identifies a taxpayer for tax-administration purposes. A VAT number identifies a business within a VAT or equivalent consumption-tax system.

The identifiers may share an underlying number in some jurisdictions and be separate in others. For CRS purposes, the relevant identifier is the TIN, or accepted equivalent, associated with the entity in its jurisdiction of tax residence.

For example:

• Poland: a company’s VAT number uses its standard tax identification number (NIP), with the country code “PL” added at the beginning for relevant VAT purposes.
• UK: a company’s Tax ID, known as a Unique Taxpayer Reference (UTR), and its VAT number are separate identifiers.

The relevant tax authority’s guidance explains which identifier applies.

What if a jurisdiction does not issue a TIN?

Some jurisdictions do not issue TINs to all individuals or entities. An equivalent identifier may apply, such as an accepted company-registration number.

The declaration should reflect the position in the relevant jurisdiction, including the applicable explanation where a TIN is unavailable.

Official tax-authority guidance and the OECD’s jurisdiction-specific information can help establish which identifier, if any, applies.

How can I find my company’s TIN?

The number may appear in:

• tax-authority correspondence;
• corporate tax-registration documents;
• previous tax returns; or
• an official tax-authority portal.

The OECD also publishes jurisdiction-specific information on the structure and use of TINs. Questions about a particular identifier can be directed to the relevant tax authority or the organisation’s professional tax adviser.

Is a company’s tax residence the same as its country of incorporation?

Tax residence and country of incorporation can differ.

The position depends on the domestic laws of the jurisdictions concerned, which may consider factors such as incorporation, management and control. A company can be tax resident in more than one jurisdiction.

What if my company is tax resident in more than one country?

A CRS self-certification should identify all relevant jurisdictions of tax residence, with the corresponding TINs where required.

Under UK CRS requirements applying from 1 January 2026, entities completing a self-certification must declare all jurisdictions of tax residence. They can no longer rely on tax-treaty tie-breaker rules to select a single jurisdiction for that declaration.

The wider application of tax treaties to an organisation’s tax position is a separate consideration.

Entity classification and Controlling Persons

What is an NFE?

NFE means Non-Financial Entity.

Under CRS, an entity that falls outside the definition of a Financial Institution is an NFE, classified as either Active or Passive.

FATCA uses the related term NFFE, meaning Non-Financial Foreign Entity. Classifications are assessed under each framework’s respective rules.

For example, an operating business such as a software development agency, manufacturing company, e-commerce retailer or consulting firm may meet an Active NFE category, while an entity whose income and assets are predominantly passive may fall within Passive NFE status. The complete criteria relevant to the organisation still need to be considered.

What is the difference between an Active NFE and a Passive NFE?

An NFE can qualify as Active through several categories.

One commonly used test requires both:

• less than 50% of its gross income for the preceding calendar year or other appropriate reporting period to be passive income; and
• less than 50% of its assets during that period to produce, or be held to produce, passive income.

Other categories cover certain publicly traded entities and related entities, government bodies, international organisations, central banks, qualifying non-financial holding companies, start-ups, entities in liquidation or reorganisation, treasury centres and non-profit organisations.

A Passive NFE is generally an NFE that does not meet an applicable Active NFE category. Classification requires consideration of the complete criteria relevant to the organisation.

Is a holding company automatically a Passive NFE?

A holding company’s classification depends on its purpose, structure and activities.

Certain holding companies within non-financial groups can qualify as Active NFEs. The subsidiaries’ activities and the wider purpose of the entity are relevant to that assessment.

Is rental income always passive income?

Rents are included within passive income in many circumstances.

HMRC guidance recognises an exception for rents and royalties derived through the active conduct of a trade or business carried on, at least in part, by employees of the NFE.

A property-related business therefore needs to consider its activities, income and assets alongside the wider classification criteria.

What is a Controlling Person?

A Controlling Person is an individual who exercises control over an entity.

Under CRS, financial institutions identify Controlling Persons using applicable anti-money laundering and know-your-customer procedures, or substantially similar procedures. Specific provisions apply to trusts and other legal arrangements.

Is a Controlling Person the same as an Ultimate Beneficial Owner?

The concepts frequently overlap.

Ultimate Beneficial Owner, or UBO, describes the individual who ultimately owns or controls an entity. Controlling Person is the terminology used in the CRS framework.

The same individual may meet both descriptions in a straightforward corporate structure. More complex structures and legal arrangements require consideration of the relevant definitions.

When is tax information needed for Controlling Persons?

Where a company is a Passive NFE, the financial institution needs to identify its Controlling Persons and determine whether any are Reportable Persons.

Depending on the circumstances, the information requested may include:

• the individual’s name;
• residential address;
• jurisdictions of tax residence;
• relevant TINs;
• date of birth; and
• controlling role.

Keeping self-certification information up to date

Why might a financial institution ask for tax information again?

A further request can arise because information is incomplete or inconsistent, the organisation’s circumstances have changed, or updated reporting requirements require additional information.

The institution may need confirmation that existing details remain accurate, an updated declaration or clarification of information already held.

How long does a CRS self-certification remain valid?

A self-certification can generally continue to be relied upon while its information remains correct and reliable.

If a financial institution knows, or has reason to know, that it has become incorrect or unreliable, further confirmation or an updated self-certification may be needed.

What can count as a change in circumstances?

A relevant change is one that affects the reliability of information previously supplied.

Depending on the organisation, this could involve changes to:

• tax residence;
• address;
• ownership or control;
• corporate structure;
• business activities;
• entity classification; or
• the individuals who qualify as Controlling Persons.

The implications depend on the circumstances and the information already held.

Can a financial institution complete the declaration for a company?

HMRC guidance permits financial institutions to pre-populate certain information already held in their records. The company’s jurisdictions of tax residence are specifically excluded from that provision.

The company must still review and positively affirm the information in its self-certification through someone authorised to act on its behalf.

What happens if information is incomplete or inconsistent?

The financial institution may request missing details, clarification, supporting information or an updated declaration.

It may also need to complete further due diligence before concluding the relevant review.

Where required information remains incomplete, this may affect the financial institution’s ability to complete the relevant review or provide certain services. HMRC’s penalty framework also provides for penalties in certain circumstances where Reporting Financial Institutions or self-certification providers fail to meet applicable requirements.

The required follow-up depends on the entity, the information held and the applicable rules.

UK reporting: the 2026 changes and the 2027 deadline

What information may be reported under CRS?

For a Reportable Account, the information can include:

• the account holder’s name;
• address;
• jurisdictions of tax residence and TINs;
• the account number or equivalent;
• the account balance or value;
• specified financial information; and
• the identity of the Reporting Financial Institution.

Information about Reportable Controlling Persons is included where applicable. The precise reporting requirements depend on the account and circumstances.

What changed under UK CRS requirements from 1 January 2026?

The updated framework, often called CRS 2.0, introduces additional reporting information for the 2026 calendar year onwards.

This includes:

• whether a valid self-certification has been provided for each relevant Reportable Account Holder and Reportable Controlling Person;
• certain Controlling Person roles; and
• account type and whether an account is a New Account or a Pre-existing Account.

Entities completing a UK CRS self-certification must also declare all jurisdictions of tax residence under the rules applying from 1 January 2026.

These are selected changes relevant to the questions covered in this FAQ.

Why are financial institutions reviewing tax information during 2026?

The additional reporting requirements make the completeness and reliability of underlying customer information particularly important.

Financial institutions may review existing records, request missing information or ask account holders to confirm that their details remain accurate.

Collecting information ahead of the reporting deadline allows time for review and follow-up where clarification is needed.

When is the UK CRS reporting deadline for the 2026 calendar year?

UK Reporting Financial Institutions report CRS information to HMRC by 31 May following the reporting year.

The first UK reporting year for CRS 2.0 is the calendar year ending 31 December 2026, with the relevant reports due to HMRC by 31 May 2027.

Account holders provide the self-certifications requested by their financial institution according to the timescales communicated to them. The institution’s information-collection timetable and its HMRC reporting deadline serve different stages of the process.

Where can I find further information?

The institution requesting a self-certification can clarify which information it needs and how to submit it.

Questions about an organisation’s tax residence, appropriate TIN or entity classification should be directed to the relevant tax authority or an independent professional adviser.

HMRC, OECD and the US Internal Revenue Service (IRS) materials provide further technical detail.

Official sources and further reading

• OECD: Consolidated text of the Common Reporting Standard
• IRS: Foreign Account Tax Compliance Act (FATCA)
• HMRC International Exchange of Information Manual: Entity self-certification
• HMRC International Exchange of Information Manual: Validity of self-certification
• HMRC International Exchange of Information Manual: Account holders and tax residence
• HMRC International Exchange of Information Manual: Tax Identification Numbers under CRS
• OECD: Jurisdiction-specific Tax Identification Number information
• HMRC International Exchange of Information Manual: Non-Financial Entities
• HMRC International Exchange of Information Manual: Controlling Persons
• HMRC International Exchange of Information Manual: CRS reporting timetable
• HMRC: Automatic Exchange of Information for account holders