Section 32A (10) of Mutual Legal Assistance (Tax Matters) Act, Revise Edition 2020 allows Reporting Financial Institutions to align the scope of Beneficiaries as controlling Person with the scope of beneficiaries treated as a reportable persons.
If the reporting FI elects this approach, Section 32A (11) and (12) of the MLA indicates that the Reporting Financial Institution must have appropriate procedures in the place to identify when a distribution is made. Additionally, an internal record of this option should be kept as part of its policies and procedures. There is nothing to report to the ITA when this option is used by the RFI but the RFI must be ready to demonstrate that it has elected to use this option where it is subject to a compliance review by the Compliance Unit.