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The German Federal Ministry of Finance (BMF) has officially published the finalized 2025 list of jurisdictions participating in the automatic exchange of financial account information under § 1(1) of the Financial Account Information Exchange Act (FKAustG). This list, critical for multinational enterprises and financial institutions operating cross-border, is now accessible on the Federal Central Tax Office (BZSt) website.
Major Changes in the 2025 Exchange List
The finalized list introduces notable shifts in Germany’s information exchange relationships:
- Belize’s Status Upgrade: From the 2024 reporting period onwards, Germany will enter a reciprocal exchange agreement with Belize, transitioning from a prior unilateral relationship. Consequently, financial data for Belizean accounts must now be reported to the BZSt.
- Newly Included Jurisdictions: Armenia, Moldova, Uganda, and Ukraine join the reciprocal exchange regime for the first time as of the 2024 reporting period.
- Visual Change Indicators: All amendments compared to the 2024 finalized list are marked in blue for ease of identification.
These modifications underscore Germany’s expanding commitment to global tax transparency and enforcement of international tax compliance standards.
CRS System Maintenance and Reporting Implications
Scheduled maintenance for the Common Reporting Standard (CRS) system will occur between June 27 and July 2, 2025. Importantly, taxpayers and reporting institutions can continue to submit their CRS filings without interruption. However, stakeholders should anticipate potential delays in receiving processing confirmation reports during this period.
Critical Compliance Reminder: GIIN Alone Does Not Confirm Financial Institution Status
Under §§ 9–18 FKAustG and § 5(1) FATCA-USA Implementation Regulation, German reporting financial institutions bear the responsibility to correctly classify reportable accounts. A crucial compliance point clarified by the BMF is:
- Possession of a Global Intermediary Identification Number (GIIN) alone is not sufficient to classify an account holder as a financial institution.
- The IRS grants GIINs based on application, without substantive verification of the entity’s financial institution status under German or FATCA regulations.
- Entities without financial institution status may hold a GIIN, which may mislead reporting entities.
- Rigorous due diligence procedures remain mandatory to avoid underreporting of reportable accounts.
Failure to perform proper classification and reporting can lead to significant regulatory risks and penalties.
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