The EMA sent a letter to the Lithuanian State Tax Inspectorate regarding the Common Reporting Standards (“CRS”) and US Foreign Account Tax Compliance Act (“FATCA”).
In the letter, the we raise three issues of concern in relation to implementation of the CRS and FATCA in Lithuania, specifically the scope of the law as it applies to Electronic Money Institutions (“EMIs”), Payment Institutions (“PIs”), and electronic money (“e-money”) and unregulated payment products issued by Credit Institutions (“CIs”), which we believe to be out of scope of the CRS and FATCA.