New accounts considered as "foreign" to be declared on 3916

Hi All,


just posted this message in reply to a 2020 thread, thinking it was from this year (doh!) so I am starting a new one to make sure it is seen and relevant.

I am also having issues with the 3916 because all the latest literature I have read (French tax notices, government information and 3rd party websites) say that we now have to declare foreign currency exchange accounts such as Transferwise (now “Wise”) and Paypal accounts - I have both.

For example, says the following:

Vous devez déclarer les comptes ouverts à l’étranger auprès d’un établissement bancaire ou de tout autre organisme ou personne (notaire, agent de change, etc.). Vous devez aussi déclarer les contrats d’assurance vie.

However the 3916 form does not seem to be adapted to these types of account. For Transferwise as an example, the money is transferred via THEIR account to my account and they say that I do not have a declarable account with them.

The form also asks you to tick a box saying you are either the open bank account owner or have power of attorney - neither is applicable… so I don’t know how to fill out this section this year (and its doing my head in!).

Transferwise have suggested consulting a local tax lawyer but I wanted to check with SFN, font of all knowledge first!

Any advice / info / clarification greatly welcomed. Thanks in advance,


Have you looked through the #stayontopic postings for 2021 which deal with the new form 3916 and what needs to be declared and how to do so?
You can find the topic here which also includes a guide on how to complete the return.
The #stayontopic thread is specifically set aside for dealing with 2021 tax returns to avoid questions neing spread around the site where people might miss important aspects and for that reason, if you agree, perhaps @cat can lock this topic to concentrate on the one already running.

I agree with the stay on topic thread in principal, but once a thread gets long then it actually helps to have a same/similar question raised again.

I have no idea what to do with my Wise account and have done nothing so far, so this reminder was useful.


Don’t be so pedantic.
Danielle is just asking for help.

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I am certainly declaring mine. But then I also hold a euro and a £ “pocket” with them, which have IBAN numbers, so obviously they need declaring.

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Just looked at the stay on topic topic, and still not sure! I have no wallets, no nothing as only used Wise to transfer money so couldn’t see anything in that thread which answered this specific question.

The answer to this query is already provided in the #stayontopic thread Jane.
The account is declarable (under the -BIS) aspect of the combined 3916 form.
I really don’t see the problem in declaring it.

@james - what do you think?

Danielle - is any of the information above on the picture confidential?

Thank you, the long PowerPoint guide is very helpful indeed, if somewhat buried in the thread. I simply had no idea that #stayontopic had anything to do with tax, not having been on SFN for quite some time (I assumed it was what it said on the tin - a reminder to stay on topic!). Was blissfully unaware!

And when I used the search function to look for “declaring foreign bank accounts”, the most relevant looking thread that came up turned out to be the one from 2020… and didn’t answer my question. So, not immediately evident how to find the relevant info for my question. Apologies again.

If I understand the guide correctly, I should declare Transferwise and PayPal as ‘comptes actifs numériques’, then mark them as ‘autre’ then tick that I’m the account owner? - ie of the Transferwise account rather than the bank account (their reference to ‘compte bancaire’ here was what was putting me off as I thought I would be admitting to having a Transferwise ‘bank account’ which is not the case…

Hope I’m on track now!!

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I can see no downside to declaring an account/accounts with Wise unnecessarily.

The downside of NOT declaring could be expensive. Acquaintances of ours were fined 6,000 euros for having missed off (by mistake) one of their UK accounts that they had declared in a previous year.


I’m not sure that’s required as you have posted the link to the original topic, we have to have some more ethereal threads even if they are on the same subject don’t you reckon?

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But is it, if never used as a “bank account”. That question is not really answered. Sure perhaps it is easier to declare than not declare but the number of accounts we are having to declare is getting a bit silly in comparison to interest declared. So could perhaps spark tax person’s interest in checking we are actually declaring all our interest (we are).

You have my view James. I don’t see a compelling reason to change it.

Hmm, good question, I don’t think so unless you reckon someone could misuse our tax reference numbers just by knowing them? Not sure they could do anything with it but I may be naive… feel free to delete the attachment if you can or let me know how to do it if you feel it best?

I would be tempted to delete it (click on the pencil at the bottom). I can’t do it for you.

With names, references and account numbers a bad person may be able to do something with it.

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Just to add to Mat’s post, the pencil icon under the post with the graphic.

I did my tax return yesterday and for the first time i added my transfer wise details.
It’ seemed logical to me. I use it several times a year just to transfer. Why not give them the account number its no Big deal.

Unless I’m missing something here regarding transfer accounts I dont see that declaring such a so called 'account’s is relevant.
I use Currencyfair as a transfer tool who I employ to exchange the sterling I have declared on my tax return.
Currency transfer companies are providers of a service, they are not a bank account.
I should add that the annual tax forms are for us to declare our income and not what we choose to do with that income once it is declared ie. To buy another currency.

Depends on the “account” John. Our tax adviser says OH’s Currency Fair “account” does not need declaring because it is just money moving through their forex department. My accounts with Wise on the other hand DO need declaring. They are “wallets” “pockets” - whatever you like to call them - where I can deposit either sterling or euros (or other currencies as well, if I so wish) and each wallet has its own IBAN number - it is a bank account in effect. For example my Wise euro account has a Belgian IBAN number.

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