Customer tax integrity | SIRA
In compliance with national and international regulations, financial institutions are responsible for assessing tax-related risks associated with customers. To guide this, the Dutch Central Bank (DNB) has issued specific recommendations under the Systematic Integrity Risk Analysis (SIRA) framework to help organizations implement effective customer tax integrity checks.
We specialize in helping financial institutions meet the Dutch Central Bank (DNB) requirements for Systematic Integrity Risk Analysis (SIRA) with a specific focus on client tax integrity. Although SIRA legislation is specific to the Dutch financial services sector, it applies to both Dutch banks as well as to Foreign banks with a Dutch branch, corporate service providers and .
Key Components of DNB’s SIRA Guidance are twofold and are based on the internal procedures and your ‘own’ profile and the risks towards its clients.
Internally focussed integrity and risk analysis
Governance and internal controls: Firms must implement a robust governance framework, including clear policies and a risk appetite statement (RAS), training programs for staff, and internal controls to ensure tax integrity risks are managed effectively.
Record-keeping: Institutions should maintain detailed records of all due diligence efforts, risk assessments, and actions taken to mitigate tax risks. These records help demonstrate compliance with legal and regulatory obligations.
Collaboration with Tax Authorities: DNB emphasizes the importance of cooperation with tax authorities to ensure transparency and compliance with international tax reporting standards, such as the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS).
Externally focussed integrity and risk analysis
Risk assessment: Financial institutions must identify and evaluate potential tax risks linked to their customers. This involves assessing the likelihood of customers engaging in tax evasion or non-compliance, and the impact this could have on the institution.
Customer Due Diligence (CDD): Institutions are required to conduct thorough due diligence on customers, including verifying tax residency, identifying beneficial owners, and ensuring tax declarations align with customer profiles. High-risk customers may warrant enhanced due diligence measures.
Monitoring and reporting: Continuous monitoring of customer transactions is necessary to detect unusual or suspicious behavior that may suggest tax evasion. Institutions must report suspicious activity to relevant authorities in accordance with legal obligations.
Implementation
By focusing on key areas such as risk identification, compliance monitoring, and mitigation strategies, we ensure that financial institutions are well-protected from potential tax integrity risks. Proper SIRA implementation not only helps meet regulatory expectations but also safeguards against financial and reputational damage.
Our services include:
SIRA IMPLEMENTATION
We help implement SIRA frameworks that align with DNB standards, ensuring financial institutions can meet their regulatory obligations.
ADVISORY
CLASSROOM
Basic and advanced training.VIRTUAL
Same as classroom, delivered via livestream.E-LEARNING
Developed upon request, e.g. web-based or SCORM file.
TRAINING
Want to know how we can assist? Contact us at: info@tripletax.eu.