[3] Tax information

As a financial institution, Solaris must comply with various tax regulations, including the Common Reporting Standard (CRS) developed by the Organization for Economic Cooperation and Development (OECD) and the German Steuerumgehungsbekämpfungsgesetz (StUmgBG).

Therefore, Solaris must collect the tax information from all individuals and legal entities that are tax residents of a reportable jurisdiction (i.e., a jurisdiction that's obliged under CRS to exchange tax information with other reportable jurisdictions).

The tax information of a person or a business (legal entity), such as tax identification number (TIN) and the tax residency (the country where the customer is taxable) is stored in a tax_identification resource on Solaris' system.


Tax identification resource types

There are two types of tax identification resources:

  1. Person tax identification: Used to store the tax information of the following customer types:
  • Retail customers (B2C)
  • Authorized persons on a retail account
  • Freelancers
  • Business' natural persons, such as legal representatives, beneficial owners, and authorized persons.

For more information, check the API reference.

  1. Business tax identification: Used to store the tax information for a business' legal entity.

For more information, check the API reference.

The following diagram describes the resources that you need to create to store tax information:

Diagram: Tax information resources


When is tax identification required?

Whether you need to collect the tax information from your customers depends on the product you're integrating, the branch, and the customer type.

The following table gives an overview of the use cases where tax information is mandatory for onboarding:

Table: Tax identification requirements

Digital Banking & Cards

For all Digital Banking and Cards products (including Consumer Decoupled Cards and Credit Cards), collecting the customer's tax information is mandatory for all customer types in all branches.

Therefore, in your onboarding flow, you need to collect the tax information from the following customer types:

B2C & freelancers

  • Retail customers (B2C)
  • Freelancers
  • Authorized persons on a retail account

B2B customers

For business customers, you need to collect two types of tax information:

  • Tax information of the business' legal entity and store it in a business tax identification resource.
  • Tax information of all natural persons linked to the business, such as legal representatives, beneficial owners, any authorized person on the business' account and store each in a person tax identification resource.
attention

Submitting the tax information of your customers is a requirement to open a bank account in all of Solaris branches. However, please note the following:

  • For customers in Germany (DE branch), you can open the bank account for the customer before providing the tax information. However, you must submit the customer's tax information to Solaris within 90 days of opening the account or otherwise the customer's account will be blocked with the reason MISSING_TAX_INFORMATION until you submit the required tax information.

  • For all other branches apart from DE, you must submit the tax information of the customer from the beginning of the flow before an account can be opened.

Standalone Lending

For lending products, collecting tax information depends on the customer type and country.

B2C & freelancers

If you're onboarding B2C customers or freelancers on a lending standalone product (e.g., not as an add-on to a standard bank account), tax identification becomes mandatory in the following cases:

  • Customers in countries other than Germany (as the tax identification is used for the credit scoring process).

B2B customers

If you're onboarding B2B customers on a lending standalone product (e.g., B2B fronting loans or fronting factoring), tax identification is mandatory in all branches, including the following:

  • Person tax identification for all natural persons associated with the business (e.g., legal representatives, beneficial owners, and authorized persons).

Standalone KYC

If you're only integrating one of the KYC methods as a standalone product without provisioning any other banking solution to your customers, tax identification is NOT required.


How to collect tax information?

In your onboarding flow, you need to integrate the collection of the customer's tax information while considering the following requirements:

Legal screens

In your sign-up flow, you need to include the required screens and declarations as explained in the legal and compliance requirements section.

Tax Identification Number (TIN) per country

Each country has its syntax validation rules for the Tax Identification Number (TIN) described as follows:

Germany

German TINs have the following charachteristics, which are used for syntax validation:

  • 11 numeric digits.
  • The first digit can not be 0.
  • Within the first 10 digits one digit appears twice.
  • All other 8 digits appear only once.
  • The last digit is a check digit which is calculated based on the previous 10 digits.

Syntax example:

  • First 10 digits: 4895437120
  • Check digit: 7
  • TIN: 48954371207

France

French TINs have the following charachteristics, which are used for syntax validation:

  • 13 digits (all numeric) C1, C2, C3, C4, C5, C6, C7, C8, C9, C10, C11, C12, C13
  • C1 must be 0, 1, 2 or 3
  • C11, C12, C13 are check digits calculated as follows:
    • Concatenate C1 until C10.
    • Get modulo 511 of the the concatenated number.
    • Check digit = remainder of modulo 511 (if remainder < 100, C11 = 0; if remainder < 10, C11 & C12 = 0; if remainder = 0, C11, C12 & C13 = 0).

Syntax example:

  • C1-C10: 3023217600
  • 3023217600 mod 511 = 53
  • C11-C13: 053
  • TIN: 3023217600053
attention

For customers opening an account in the French branch, please note the following rules:

  • If the customer's tax residency is in France, collecting the tax ID is NOT mandatory. However, you should still pass this information to Solaris similar to the below example.
  • If the customer's tax residency is NOT in France, collecting the tax ID is mandatory in your frontend flow.

Customer with a tax residency in France

If the customer's tax residency is in France, collecting the tax identification number is not mandatory. However, you need to pass the following information for the customer by calling the POST Create a person tax identification endpoint.

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// POST /v1/persons/{person_id}/tax_identifications
{
  "country": "FR",
  "reason_no_tin": "OTHER",
  "reason_description": "Not required since FR resident with tax residency in FR"
}

Italy

The Italian equivalent of the TIN is the codice fiscale. It is calculated by a legally established algorithm and must be verified by your frontend implementation.

Italian TINs have the following charachteristics, which are used for syntax validation:

  • Format "SSSNNNYYMDDZZZZX"
  • SSS alphabetical
  • NNN alphabetical
  • YY numerical, last digits of the birth year
  • M is the letter for the month of birth—letters are used in alphabetical order, but only the letters A to E, H, L, M, P, R to T are used (thus, January is A and October is R)
  • DD is the day of the month of birth (particularities like leap years are considered, in order to differentiate between genders, 40 is added to the day of birth for women (thus a woman born on May 3 has ...E43...))
  • ZZZZ 1. alphabetical, 2-4 numerical
  • X alphabetical
  • syntax example: SSSNNN31B28X000C

Codice fiscale validation

Please refer to the decree of the Finance Ministry for the source of this algorithm.

Example: RSSMRA99D20F205R

Position12345678910111213141516
DigitRSSMRA99D20F205R
Position in fiscal codeMeaning of digitsHow it is computed
1-3Last nameLast names composed of multiple parts are always considered as a continuous sequence of characters; For women, this is always the maiden name; If the surname has three or more consonants, then the first, second, and third consonants are used; If the surname has two consonants, then the first and second consonants and first vowel are used; If the surname has one consonant and two vowels, then the first consonant and then the first and second vowels are used; If the surname has one consonant and one vowel, then the first consonant is used, then the first vowel, then "x"; If the surname has only two vowels, then the first and second vowel are used, followed by "x".
4-6First nameLast names composed of multiple parts are always considered as a continuous sequence of characters; If the first name has three or more consonants, then the first, second, and third consonants are used; If the first name has two consonants, then the first and second consonants and the first vowel are used; If the first name has one consonant and two vowels, then the first consonant and the first and second vowels are usedd; If the first name has one consonant and one vowel, then the first consonant and first vowel are used, followed by "x"; If the first name has only two vowels, then the first and second vowel are used, followed by "x".
7-8Year of birthLast two digits of the birth year (e.g., for customers born in 1975, these digits would be 75).
9Month of birthThe month is assigned a letter based on the rules described in table 4 (e.g., if a person is born in June, this digit would contain the letter H).
10-11Day of birth & genderThese two digits are computed based on the gender. For male persons: the digits correspond with the exact date of birth (01 to 31); For female persons: the digits correspond with the exact date of birth + 40, so value is from 41 to 71. E.g., if a female person is born on the 10th day in the month, then these two digits would be 50. The birth month assigned a letter based on the rules described in table 4 (e.g., if a person is born in June, this digit would contain the letter H).
12-15Place of birthThese digits consist of one letter and three numbers. For persons in Italy, then they represent the town and province of birth; For persons outside of Italy, then they represent the country of birth.
16Control characterThe digits at the even positions are converted to the values listed in Table 1; The digits at the odd positions are converted to the values listed in Table 2; The resulting numbers are summed and divided by 26; Then, this resulting number is converted to the letter that corresponds with its numeric value, as described in Table 3.
DuplicatesIn the event that the first 15 digits of an existing codice fiscale would be the same for two or more persons, there is a method to avoid creating a duplicate codice fiscale once it has been registered. The first number of the codice fiscale starting from the right is converted to a letter as described in Table 5. E.g., for the second person with same codice fiscale, the first number from the right is converted to a letter; for the third person with the same codice fiscale, the first and second numbers from the right are converted to letters.

Table 1

CharacterValueCharacterValueCharacterValueCharacterValue
0099I8R17
11A0J9S18
22B1K10T19
33C2L11U20
44D3M12V21
55E4N13W22
66F5O14X23
77G6P15Y24
88H7Q16Z25

Table 2

CharacterValueCharacterValueCharacterValueCharacterValue
01921I19R8
10A1J21S12
25B0K2T14
37C5L4U16
49D7M18V10
513E9N20W22
615F13O11X25
717G15P3Y24
819H17Q6Z23

Table 3

CharacterValueCharacterValueCharacterValueCharacterValue
0A7H14O21V
1B8I15P22W
2C9J16Q23X
3D10K17R24Y
4E11L18S25Z
5F12M19T
6G13N20U

Table 4

MonthValueMonthValueMonthValueMonthValue
JanuaryAAprilDJulyLOctoberR
FebruaryBMayEAugustMNovemberS
MarchCJuneHSeptemberPDecemberT

Table 5

CharacterValueCharacterValueCharacterValueCharacterValue
0L3P6S9V
1M4Q7T
2N5R8U

Spain

The Spanish equivalent of a TIN is the NIF (Número de Identificación Fiscal).

  • for Spanish citizens, the TIN value is the same as the National ID (DNI - Documento Nacional de Identidad) and contains 8 digits and 1 letter. The format is 00000000-A, where 0 is a digit and A is a checksum letter.
  • for non-citizens in Spain, the TIN value is the same as Foreigner ID (NIE - Número de Identidad/Identificación de Extranjero) and contains 7 digits and two letters (1 letter at the beginning and 1 letter at the end). The format is X-0000000-A, where 0 is a digit, A is a checksum letter, and X is a letter generally X but lately also Y.

DNI issuing is regulated under the Royal Decree no. 1553/2005 issued December 23rd. Article 11 states that the DNI document includes the personal national identification number and a checksum letter corresponding to the tax identification number.

Tax identification numbers of adult Spanish citizens can be verified by calculating their checksum letter using the following algorithm:

The number is divided by 23 and the remainder is replaced by a letter determined by the following table:

REMAINDER01234567891011
LETTERTRWAGMYFPDXB
REMAINDER1213141516171819202122
LETTERNJZSQVHLCKE

For example, if the DNI number is 12345678, divided by 23 leaves a remainder of 14, therefore the letter is Z: 12345678Z.

Non-citizens in Spain have a NIE (Número de Identidad de Extranjero) which is made up of a letter (X, Y, Z), 7 numbers and a check digit.

To calculate the check digit, each letter is replaced by a number and the same algorithm can be used:

  • X → 0
  • Y → 1
  • Z → 2

Tax ID validation

Solaris's syntax validation rules for tax IDs enable you to verify your customers' tax identification numbers (TIN) on the spot and reduce wrong entries.

The Solaris API automatically validates the format of the supplied tax identification number (TIN) based on the requirements of the customer's country. If the TIN does not follow the proper format, the API will return a 400 error.

note

The tax ID validation is only available for person tax identifications, such as retail customers and freelancers, and not businesses. It's activated by default for new customers.

Invalid tax ID 400 error example

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{
    "errors": [
        {
            "id": "029f7bc9-a4dc-4512-b3ee-65d2eb089804",
            "status": 400,
            "code": "invalid_model",
            "title": "Invalid Model",
            "detail": "number is not a valid person tax identification number for country: ES, for reference please check: https://en.wikipedia.org/wiki/National_identification_number#Spain",
            "source": {
                "field": "number",
                "message": "is not a valid person tax identification number for country: ES, for reference please check: https://en.wikipedia.org/wiki/National_identification_number#Spain"
            }
        }
    ]
}