With respect to the Foreign Account Tax Compliance Act (“FATCA”), the first reporting by Luxembourg financial institutions is due on 30 June 2015 at the latest. This reporting concerns information pertaining to 2014.
On 6 March 2015, the Luxembourg Government adopted Bill of Law 6798 for the ratification of the Intergovernmental Model I Agreement signed between the United States and Luxembourg on 28 March 2014 (“IGA”). The Bill was submitted on 27 March 2015 to the Luxembourg Parliament. For further details please refer to our February Newsletter.
It should be stressed that reporting Luxembourg financial institutions are considered as data controllers according to Luxembourg data protection rules and must inform individuals falling within the scope of the automatic exchange of information under the IGA that the information will be collected and transferred in accordance with the IGA.