Effective Date: 30 July 2018
Pursuant to and in accordance with clause 7.2 of the Subscription Agreement, the following Assumptions, Exclusions, Qualifications and Disclaimers apply to all CRS report outcomes generated by the CRS Expert Software (“Report”).
1. ASSUMPTIONS
The following assumptions apply to all CRS Expert Report outcomes and analysis:
1.1 All indicated Financial Accounts were created and or established on or after the date on which the jurisdiction of residence of the relevant Financial Institution which maintains the relevant Financial Accounts first adopted the CRS;
1.2 All Financial Account values are assumed to be more than USD$250,000.00 at all material times;
1.3 The choice of icon(s) used in creating a unique structure chart is accurate and complete;
1.4 That each person and entity indicated on the unique structure chart is tax resident in the country or countries indicated.
2. EXCLUSIONS
2.1 The Report does not express and is not to be read as expressing any opinion in relation to any other means by which countries might exchange financial and/or tax related information whether automatically, on request or spontaneously, and whether as a result of a double tax treaty or otherwise. Application of the US Foreign Account Tax Compliance Act (FATCA) is unsupported at this time.
2.2 The Report does not express and is not to be read as expressing any opinion in relation to Council Directive 2011/16/EU (as amended and supplemented) of the European Union.
2.3 The Report does not express and is not to be read as expressing any opinion in relation to domestic regulatory and or legislative adoption of the CRS by any jurisdiction implementing the CRS.
3. QUALIFICATIONS
3.1 The Report is generated in respect of Financial Accounts held and/or created during the year 2018 and does not apply to any period before 2018.
3.2 Relevant “Reportable Jurisdiction” and “Participating Jurisdiction” country lists are subject to periodic update and amendment. Reasonable efforts are made to keep up to date Reportable and Participating Jurisdiction for each member of the CRS Multilateral Competent Authority Agreement. Real time Reportable and Participating Jurisdiction lists are not at this stage supported.
3.3 The Report does not constitute and shall not be relied upon as constituting legal advice and/or assistance in relation to or in connection to any domestic rules and/or regulations implementing the CRS.
4. DISCLAIMERS
4.1 The Report is for the sole benefit of the licensed user. It may not be relied on by any other person or used for any purpose which may constitute the provision of legal advice or assistance.
