In a recent update of the IDES Technical FAQ the IRS published the statement that: “Only Direct Reporting Non-Financial Foreign Entities (NFFEs) are required to submit nil reports. For all other entities, submission of nil reports is not mandatory and submission of these reports is optional. While nil reporting might not be required by the IRS, it might be required by the local jurisdiction. Please check with your local tax administration. Nil reports that are submitted must provide Reporting FI information. The report contains Reporting Group, but it does not contain any account reports or pooled reports. Reporting group can be empty or can contain Sponsor or Intermediary information.”
Several jurisdiction already confirmed that nil reports are not required, including the UK HMRC.
The FAQ can be accessed here: http://www.irs.gov/Businesses/Corporations/FATCA-IDES-Technical-FAQs.
Please scroll down for C19 to find the text above.