CRS Confusion: Correcting a deletion

August is the month of correction for us. We will deal with corrections and deletions of messages and records submitted under the common reporting standard. In a previous post we asked what happens when you delete a correction. Today we will venture into the dangerous swamps of correction of a deletion.

When you correct a message, the CRS schema asks you to inform the recipient WHAT you want to correct. This wisdom is encapsulated in the CRS schema tag “CorrDocRefID” which is meant to contain a reference to the DocRefID of the dataset to be corrected.

Example: You want to correct a previously deleted message. Which dataset are you going to reference in your CorrDocRefID: The first message or the message that deleted the first message. The right answer seems to be to reference the latest instance of a dataset in a chain of corrections. The second question is whether you can correct a deleted message at all.  The correct approach seems to be: let those damn (in)competent tax authorities (CA) deal with it, I do not care.

However, if the CA decided that a deletion deletes everything, a correction that points to a no longer existing dataset might be rejected playing the ball back into the FI court. Tax authorities are equally confused by the silence of the CRS User Guide. The only solution is to work together, i.e. exchange information IN A TIMELY MANNER what is being implemented, why and how.

So far my impression is that tax authorities and financial institutions are scheduled to exchange bank account information in the millions, however, they have not yet learnt how to pick up a phone.

Taciturn coding will benefit no one, but, who is listening ?

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