Financial institutions must apply the due diligence procedures outlined in Annex II of the "Regulations" to identify the accounts and individuals to be reported to SUNAT, supplemented and interpreted following the CRS and its comments.
According to the Regulation, financial institutions subject to reporting shall perform due diligence on Financial Accounts held as of December 31, 2018 (pre-existing accounts) and accounts opened as of January 1, 2019 (new accounts).
Concerning each of the accounts (pre-existing or new), Financial Institutions must:
Conduct review processes to obtain the identification data of the reportable account holder(s) (if more than one) who are individuals with tax residence abroad.
Obtain the same data for the individuals exercising control by the provisions of subclause 6 of subsection D of Annex II, provided that the referred controller or controllers are individuals with tax residence abroad.
For New Accounts, financial institutions must obtain an affidavit from the account holder that determines that the account holder is a resident for tax purposes in a reportable jurisdiction, at the time the account is opened, which enables the financial institution to determine the tax residency of the account holder and controlling person, where applicable