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E-wallets and CRS (page 2)

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ilovethisforum
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« Reply #15 on: March 19, 2016, 08:30:45 PM »

Thanks a lot Looter for the valuable info
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Pete1928
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« Reply #16 on: December 29, 2016, 10:39:26 AM »

Hello everyone,


I would like to hear your educated opinion, you guys are much more informed than I am, about the updated situation of E-wallets and CRS.

On one hand, OECD website does mention e-money, however, it mentions it in the following way:

"reportable accounts are bank accounts, e-money accounts and current accounts..."


So, does this only apply to e-money accounts such as LeuPay who are connected to the bank itself, or all money accounts?


The Optimal Payments Group (which has Skrill and Neteller) has announced in 2014 that in case Isle of Man and UK enter these multilateral agreements, they would be affected, however, Skrill as you know has answered someone officially last year (DEC 2015) that they will NOT participate.

http://www.pokergurublog.com/content/skrill-states-it-will-not-be-subject-automatic-exchange-information-between-countries-rega-0

I asked them a week ago directly, however from a non-client e-mail, I didn't want to raise suspicion, if they will participate, and they replied the following:

"Thank you for getting back in touch with us.
 
As previously advised we would act in accordance with our Privacy Policy and the Terms & Conditions for the services.

Please familiarise with the documents to understand our positions. As an electronic money issuer we are subject to the law of the UK, the European Union and the International law as well as the local legislation in any country where we have local entities.

We would no be able to confirm if we will or will not have to be involved with the said programme at the moment or in the future.

We are sorry if this is causing you any inconvenience.
 
Kind regards,
Asen
Skrill Help Team"


So I see articles a year old saying e-wallets won't fall into reportable categories, but then I see on the OECD website that they do mention "e-money", does that mean all e-money or just some who are bank subsidiaries with a banking license (i.e. Skrill does not have a banking license and is not a depository institution).


I am currently very worried because I would not like them to exchange 2016. I wish I found out about this a year ago, but I am still hoping I am perhaps not late, if I close the account now and somehow e-wallets don't meet the exchange for SEPT 2017 with the early adopting countries, but I cannot be sure and this is stressing me big time.

I thought Skrill was safe, all up until now, and to be honest I can't sleep at night, I googled at least 500 different sources.


Is there any hope that 2016 won't have to sent by Skrill? So much contradicting information, my head will explode. Help guys, give a colleague some hope here. :D
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Thordin
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« Reply #17 on: December 29, 2016, 07:22:36 PM »

Some say they should participate, some that they are exempt, there is all kind of info online.
I would say it is in their best interests to try and stay out of this.

Leupay said they will participate and will let customers know what information they will give away.

Arbusers can you check if anything changed since the last answer you got from them?
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ilovethisforum
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« Reply #18 on: December 29, 2016, 07:36:33 PM »

Hello,everyone i have read that all the countries of the world will be in this CRS system until 2018.There are only 2 countries which will not be in this system.The one i didn't knew it was a country but the other IS a country.I advice you to read the documents of CRS standard and see which one will be excluded.The WHY is the best part! :D. The key part to this standard is to understand how it works,so we can beat it.I don't believe there will be a global standard of long enough time.There are too much black money that need to be parked somewhere and some countries will make everything they can to create parking spaces.
« Last Edit: December 29, 2016, 07:42:40 PM by ilovethisforum » Logged

Skaggerak
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« Reply #19 on: December 29, 2016, 08:57:35 PM »

What does it matter if one or two countries aren't in this, aren't optimal payments based in Europe? So they'll almost certainly be included in this I believe.
I'm always scaremongering when it comes to worst possible scenarios, but I think we really are looking at the end of how a lot of us operate with all these new regulations and how the industry is shrinking, there just isn't going to be enough to go around for the smaller of us I think. I'd be pretty thankful if my reason for worrying about this is that I've too much to go around.
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ilovethisforum
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« Reply #20 on: December 29, 2016, 11:13:05 PM »

What does it matter if one or two countries aren't in this

It matters a lot,because if for example a new Skrill or a new bank has their business base in one of these two countries,they will not be obliged to report to CRS,or whatever system.
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cortomaltese
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« Reply #21 on: December 30, 2016, 07:47:54 AM »

Maybe i am being naive here , but are you sure you are not worrying more than you should?
So what's the worst scenario?
Skrill/Neteller will have to report their customers data to CRS
So what? Is the funds sitting in skrill or neteller illegal? I thought that money from gambling are already taxed when withdrawed from sportsbooks , so what's the problem?
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Arbusers
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« Reply #22 on: December 30, 2016, 01:08:04 PM »

I think I already informed the community with the initial post of this thread.
I also suggested that we keep this issue low in the agenda, but some people insist bringing it up again and again.
Quoting from the HMRC's reccomendation.

“Entities that issue payment cards that can be pre-loaded with funds to be spent at a later date, such as a pre-paid credit card or “e-money” may not be Depository Institutions provided certain conditions are met. Pre-paid credit card issuers may meet the conditions to be a Qualified Credit Card Issuer which will make them a Non reporting Financial Institution or the payment card account may meet the conditions to be an Excluded Account. “E-money” providers that are governed by the provisions of the European Union Electronic Money Directive are not deposit takers for the purposes of the Banking Consolidation Directive  Recital 13 to the EMD specifically states that “The issuance of electronic money does not constitute a deposit-taking activity pursuant to Directive 2006/48/EC”, consequently such providers will not fall within the definition of Depository Institution that requires deposits to be accepted in the ordinary course of a banking or similar business. Entities that solely provide asset based finance services, such as a factoring or invoice discounting business, or that accept deposits from persons solely as collateral or security pursuant to a sale or lease of property, a loan secured by property or a similar financing arrangement, between such entity and the person making the deposit, will not be Depository Institutions. Entities that facilitate money transfers by instructing agents to transmit funds (but do not finance the transactions) will not be considered to be engaged in banking or similar business as this is not seen as accepting deposit.”

The exact link is here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/461418/Guidance_Notes_for_the_Automatic_Exchange_of_Financial_Account_Information.pdf

The e-wallets are low in the agenda, but you never know when they go to the top. The infrastructure will be ready in no time as e-wallets are more in technology than other institutions.
If you read the handbooks of CRS, you will also see 2 important details:
1st. The institution should inform the ''reporting person'' before January the 31st that his data will be reported. This should take place in the form of a letter, e-mail and likes, or in a change of terms and conditions that customers should accept.
2nd. Countries and territories have the ability to select how they interpret several parts of the standard.

I m afraid no managers are on line to discuss these things at the 30th of December.

Some more remarks from my side. The US is not bound by the CRS. The new administration has shown signs to adopt more ''capital friendly'' policies, by lowering taxes for the US companies. My guess is that Brexit will keep Britain too out of the European straight jacket.
These are only my opinions of course that you cant take as a tax advise.
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Bubbles
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« Reply #23 on: December 30, 2016, 02:12:18 PM »

Maybe i am being naive here , but are you sure you are not worrying more than you should?
So what's the worst scenario?
Skrill/Neteller will have to report their customers data to CRS
So what? Is the funds sitting in skrill or neteller illegal? I thought that money from gambling are already taxed when withdrawed from sportsbooks , so what's the problem?
My sentiments exactly

It was an issue a few years ago if one had a stash in a tax jurisdiction better than one's own. But now 1) we already have “USSR of EU” and we've been living with it for some time, annoying but possible, 2) OECD will force further and further transparency so for ewallets it's only a question of when, 3) nobody I hope is that stupid to keep their stash in an ewallet?!
Knowing as much as we know at this stage I can't see a clear picture of how it can turn our world upside down. Maybe with arrival of new informations this picture will start to emerge but for today imho there are enough more important problems to worry about
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Narber
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« Reply #24 on: December 30, 2016, 05:41:53 PM »

“Entities that issue payment cards that can be pre-loaded with funds to be spent at a later date, such as a pre-paid credit card or “e-money” may not be Depository Institutions provided certain conditions are met. Pre-paid credit card issuers may meet the conditions to be a Qualified Credit Card Issuer which will make them a Non reporting Financial Institution or the payment card account may meet the conditions to be an Excluded Account. “E-money” providers that are governed by the provisions of the European Union Electronic Money Directive are not deposit takers for the purposes of the Banking Consolidation Directive  Recital 13 to the EMD specifically states that “The issuance of electronic money does not constitute a deposit-taking activity pursuant to Directive 2006/48/EC”, consequently such providers will not fall within the definition of Depository Institution that requires deposits to be accepted in the ordinary course of a banking or similar business. Entities that solely provide asset based finance services, such as a factoring or invoice discounting business, or that accept deposits from persons solely as collateral or security pursuant to a sale or lease of property, a loan secured by property or a similar financing arrangement, between such entity and the person making the deposit, will not be Depository Institutions. Entities that facilitate money transfers by instructing agents to transmit funds (but do not finance the transactions) will not be considered to be engaged in banking or similar business as this is not seen as accepting deposit.”

The exact link is here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/461418/Guidance_Notes_for_the_Automatic_Exchange_of_Financial_Account_Information.pdf

The e-wallets are low in the agenda, but you never know when they go to the top. The infrastructure will be ready in no time as e-wallets are more in technology than other institutions.
If you read the handbooks of CRS, you will also see 2 important details:
1st. The institution should inform the ''reporting person'' before January the 31st that his data will be reported. This should take place in the form of a letter, e-mail and likes, or in a change of terms and conditions that customers should accept.
2nd. Countries and territories have the ability to select how they interpret several parts of the standard.

IMO, the fact that e-wallets are not depositionary instutions, does not make them non reporting financial institutions. The CRS is not limited just to banks.

From this link you can find institutions which are reporting and non-reporting:

https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim400600

I'm still confused why Skrill is not willing to disclose publicly what information they will (or will not) share.

EDIT: The guidance linked in the first post has been superseded by guidance made on May 16 2016, and it looks like e-wallets were added as Financial institutions in that guideline. See following link, specifically part IEIM400750: https://haydonperryman.com/gb/guidance/dac/
« Last Edit: December 30, 2016, 05:59:05 PM by Narber » Logged

fairpunter
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« Reply #25 on: December 30, 2016, 07:32:29 PM »

Don't worry about it guys, e-wallets will not included in CRS list.
If e-wallets join to CRS, I will request to close my arbusers account.
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Pete1928
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« Reply #26 on: December 30, 2016, 10:13:45 PM »


EDIT: The guidance linked in the first post has been superseded by guidance made on May 16 2016, and it looks like e-wallets were added as Financial institutions in that guideline. See following link, specifically part IEIM400750: https://haydonperryman.com/gb/guidance/dac/

This looks very worrying to be honest, this particular update, classifying them as financial institutions.

THe only hope I have is that they won't be reporting it for 2016, or just the balances like some German banks will, not the entirety of the annual transactions and its details.


Quote from: fairpunter
Don't worry about it guys, e-wallets will not included in CRS list.
If e-wallets join to CRS, I will request to close my arbusers account.

I wish I could be as sure as you are, man, I would be the happiest man right now. :)

Btw, I still think when Arbusers asks the managers in early Jan on the updates, that THIS will be the most updated and accurate information, they will be able to tell us early on what's going to happen.

It's a massive difference if they only report balances on 31.12.2016., than the details of transactions, etc.

Let's hope for the best at least for 2016. For 2017 I'm sure we'll come with another solutions, but 2016 is something we need a bit of luck on. Happy NY everyone, best wishes.
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Skaggerak
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« Reply #27 on: December 30, 2016, 11:55:57 PM »

It matters a lot,because if for example a new Skrill or a new bank has their business base in one of these two countries,they will not be obliged to report to CRS,or whatever system.

Just because a couple of countries won't be included doesn't mean much. Judging by how complacent Paysafe have gotten there's no way they'd be as proactive as to take an opportunity like that, look at all the complaints they get here on a daily basis.
It really seems like we're skating on thin ice judging by responses here. To even see the man himself on here saying it's low on the agenda and then getting responses from people more informed with really worrying revelations for us all is shocking. Then we get another comment saying hopefully it won't be too early in the year, like THATS the expectation we have now.
Guys, unless I'm being mistaken, Paysafe is about to join this CRS and become about as useful as Paypal. How in the hell have we got to a point where we need to rely on these guys so much. It's funny, I heard some jokes before here about the need for a new e-wallet, that maybe we could create one. It's starting to seem like a reality, but the main problem with this is NO major British sportsbooks want e-wallets anymore in my opinion.
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fairpunter
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« Reply #28 on: December 31, 2016, 07:44:20 AM »

         Who does hold and use his money on e-wallets ? - most of them traders,arbers and amateur bettors (one word - who loses his money and makes money from betting) and this is not black money.
         Black money which is earned from illegal ways. and usually black money holders can't show from where based their money and they keep their money Cash to keep themselves out of radar(tax), but sometimes black money holders keep their money in bank accounts abroad, in this situation local tax ministry can't detect them and it is great problem of governments.
         "CRS" is for against black money holders. "CRS" and "The guys who arranges betting in the world", probably they are the same associations(finance regulators). I think that they will not make bettors,trader's,arber's work harder,because this is the work which is maked by themselves.They can easily detect who is who and from where based our money, also as we know e-wallets easily share personal information with third parties, it doesn't matter it is any bookie or "CRS" for e-wallets. Maybe they will apply some transaction,deposit,withdrawal limits. IMO they will not seriously touch e-wallets.
Don't worry about it guys, enjoy christmas days with your kids.
« Last Edit: December 31, 2016, 07:46:10 AM by fairpunter » Logged

Arbusers
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« Reply #29 on: December 31, 2016, 08:20:21 AM »

To even see the man himself on here saying it's low on the agenda and then getting responses from people more informed with really worrying revelations for us all is shocking. Then we get another comment saying hopefully it won't be too early in the year, like THATS the expectation we have now.

Your criticism is unfair and you distort my words altering their meaning at your convenience. It is really sad to see this.
I would like you to pinpoint the ''people more informed'' that you mentioned so I request them to provide their insight.
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