Form 3916 covers more than just foreign bank accounts

elsie
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Form 3916 covers more than just foreign bank accounts

Post by elsie »

The fine for each undisclosed non-French bank account and/or life insurance policy is €1,500, with no maximum. The penalties for failing to declare a foreign account are the same whether it is active or not and even if you have not deposited any funds, earned any interest/gains or made any withdrawals.

There is a general description in English of the coverage at https://www.impots.gouv.fr/portail/inte ... icies-held but it is a general statement and not just for those originally from the UK. So the coverage isn't well-defined and there are always discussions on the scope.

Most financial organisations ask for tax identification numbers and they are under an obligation to report to the relevant tax authorities. So you should be reporting those.

Besides bank accounts, I think the scope can be considered to include any other foreign account where you have deposited funds. That can include premium bonds, endowment policies, life insurance policies, personal pensions, non-French assurances vie, ISAs, money transfer accounts (e.g. Transferwise), credit card accounts such as Monzo/Revolut/Starling, etc., stockbroker/crowdfunding startup accounts for future investments.

If you declare on paper you will need to print a form for each account. Is is possible you don't need to declare them every year and the tax office will assume the information is still relevant in following years but I've not seen any official confirmation. If you are declaring online it is easy and you only need to do it once as the data is re-displayed the following year. You need to declare accounts even if you have not deposited or withdrawn from them or if they have a zero balance. If you close an account you should declare it closed rather than just forgetting about it.

You only need to give the name and address of the financial organisation, the account type and the reference numbers. There is no need to give details of amounts deposited.

It is possible old endowment policies, life assurance policies, ISAs have never been updated to include your French tax details. That could cause problems for you if you make withdrawals in the future (or for your inheritors when you die) so you should update them and declare them. The penalties for deliberately hiding accounts are significantly greater.

From personal experience I know they do compare tax returns with the annual reports they receive from financial organisations. Many years ago I was invited to the tax office to explain why I'd only declared a small sum of interest when they had notification of a much larger sum. The report was for a UK April-April financial year and only gave basic totals. I proved the larger sum was interest deposited in February of the current year so would be declared the following year (and then we had a bit of a discussion about quarter days and pre-1911 tax years)

dasher
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Re: Form 3916 covers more than just foreign bank accounts

Post by dasher »

Hi Elsie,
Is it a new thing to have to enter all bank accounts this year? I have no recollection of doing this last year and am worried if I have not done so in the past this will land me in trouble.
I have just finished my declaration now (and am searching for last years!)
Many thanks
D.

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Re: Form 3916 covers more than just foreign bank accounts

Post by elsie »

No, it isn't new. If you look back at the notes for 3916 you will find it has been that way for many years. But possibly with paper reporting they were less interested unless they found another problem.

The link from www.impots.gouv.fr above has a section: Which accounts are concerned ?
which starts: All bank accounts and life insurance policies opened, used or closed abroad during the year. (and even that is incorrect as you should also report dormant or zero balance accounts)

Part of the problem with those 3916 notes is they are meant for anyone in France declaring accounts which could be in any country in the world. So there isn't a clear definition or a comprehensive list as each country has different types of accounts where funds could be held.

The reason for the posting was because the scope of the requirements is much wider than many assume (see the list of mainly UK-related accounts above I think should be included - and I'm not sure even that is comprehensive for just the UK) and they are tightening up more and more, especially as the amount of automatic reporting of accounts between financial institutions and tax offices is increasing.

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Re: Form 3916 covers more than just foreign bank accounts

Post by Dozzle »

Hi Elsie, thnx for info.
Just starting my 1st French tax return. :shock:
I have a foreign private pension a/c but can’t see where it should be entered on Form 3196 (it’s not a bank a/c or life Insurance a/c or a capitalisation etc & there are no other options).
Thnx

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Re: Form 3916 covers more than just foreign bank accounts

Post by elsie »

They have made significant changes to form 3916 this year and are asking for a lot more detail. It seems they are trying to collect more information to check on money-laundering.

The printable version is https://www.impots.gouv.fr/portail/form ... isation-ou

In previous years there was just a single form on which all types of accounts were declared. Now they have broken the accounts down into different types, bank, digital currency, assurance vie, etc. for different declarations and the form is now four pages for each account rather than two.

In the past it has often been assumed the information could just roll over from year to year. Now they want to start afresh. As I mentioned elsewhere there is a need to reinput all the required information in the new format. Hopefully it will then roll-over for following years.

Dozzle: to answer your specific private pension question, on the printed version section 7 is probably the correct box. You will need to tick that box in section 2 and in 7 tick Autre placement de même nature (autre) and fill in a many of the remaining details as you can.

You have to remember the form is for all sorts of different accounts from all over the world so they cannot possibly include them all in the description. And the form is probably more aimed at the French with foreign accounts than the immigrants from the UK and elsewhere.

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Re: Form 3916 covers more than just foreign bank accounts

Post by FrenchForumSurvivor »

Posted on another thread but it applies here as well.

Form 3916 applies to all those who declare in France, French and non-French alike, and I imagine the authorities will be looking for those who are not declaring large amounts of money in overseas accounts, not foreign pensioners who might have less than a couple of thousand sprinkled across various non-French accounts. In any event, declare those accounts you are sure ought to be declared, but don't panic if you think you might have forgotten something.
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Re: Form 3916 covers more than just foreign bank accounts

Post by Aardvark »

After all the promises about doing our declarations online instead of paper being soooo much quicker and easier its now going t*ts up again. Why can't they just stick with one thing and stop changing the forms every year? If they want our money they should make it easier, not more complicated. :roll:

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Re: Form 3916 covers more than just foreign bank accounts

Post by suein56 »

elsie wrote:
Sat Apr 10, 2021 12:30 pm
They have made significant changes to form 3916 this year and are asking for a lot more detail. It seems they are trying to collect more information to check on money-laundering.

The printable version is https://www.impots.gouv.fr/portail/form ... isation-ou
Thanks for that Elsie .. it's very helpful.
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Re: Form 3916 covers more than just foreign bank accounts

Post by Mangetout »

Elsie, your view please. I am someone who is very careful to fully declare since making a genuine error in our early years here which cost me 10k in back tax, interest and fines. I too have been called in to explain the difference between what my UK bank declared and what I declared. In this instance my UK bank had made an error and reported the annual interest twice, once for me and once for my husband. It took some convincing. Anyway, my question. Reading your posts, it has just dawned on me that I hold a credit card with Sainsbury bank, which has no facility to deposit funds. Any monies owed are debited from my normal bank account with one of the big 4. I have never declared it, in fact it has never crossed my mind as I don't see it as a bank account. Should I?

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Re: Form 3916 covers more than just foreign bank accounts

Post by Pale Ale »

With the new design of the 3916 form this year, and the fact that all previous entries on the 3916 have been deleted, how are people interpreting this move. Do you think that the Tax Man is giving us a gentle nudge and making us all aware of the accounts that should be declared, or do you think that it is a definite ploy to catch as many people as possible who have not declared certain accounts and whack us all with hefty fines? By reading this thread and other threads related to this years tax form, it is obvious that folks on this forum have genuinely not declared some accounts as they thought it was not necessary. I have personally not declared an old Currency Fair account that I have not used for about 4 years since I switched to Transferwise, although I have declared both mine and my wife's accounts at Transferwise.

This week I have received an e-mail from an old spread betting account that I closed last year, that I had had opened about 15 years ago, there was only about £50 in the account and I had not used it for years. They are now asking me to fill in a form stating country of residence, address etc and also asking for my Tax Identification Number, so presumably they will be passing this information on to the French tax man. I also received the same requested from the broker that I use in the UK yesterday, again asking for my TIN, I have declared this account on the 3916.

On this years 3916 I will be declaring all the accounts that I had not previously declared, as like other people on this forum I did not think that I had to. I have declared all bank accounts and broker accounts, but not the spread betting account from day 1, as I think that this seems the sensible option, rather than not declaring them and hoping for the best. Not quite sure how I will declare the closed spread betting account, as it has never shown on the 3916!

How are other people going to deal with accounts you have not previously declared?
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