What is CRS (Common Reporting Standard)?

How it works

CRS was developed by the OECD in 2014 as the global counterpart to the US FATCA regime — multilateral instead of bilateral. It went live in 2017 with first reporting waves in 2017-2018, expanding annually as more jurisdictions joined.

Mechanism:

1. Self-certification at onboarding. Banks, brokers, EMIs, and other "financial institutions" require new account holders to declare their tax residency (jurisdiction(s) where they're tax resident) and provide a TIN.
2. Annual identification of reportable accounts. Each year, the financial institution identifies accounts held by tax residents of other CRS jurisdictions.
3. Annual reporting to the local tax authority. Reporting includes account holder identity, TIN, account number, year-end balance, gross interest / dividends / other income, and gross proceeds from financial-asset sales.
4. Automatic exchange between tax authorities. The local tax authority forwards the data to each relevant foreign tax authority via the OECD's Common Transmission System (CTS).

What's reported

For each reportable account:

• Name, address, jurisdiction of residence, TIN, date of birth (individuals).
• Account number, financial institution name.
• Year-end balance (or value).
• Gross interest, dividends, gross proceeds from financial-asset sales paid to the account during the year.
• For passive non-financial entities (NFEs) with substantial owners in another CRS jurisdiction: lookthrough to the substantial owner's residence.

Coverage

110+ jurisdictions participate, including:

• All EU member states + UK + Switzerland.
• Major financial centres: Singapore, Hong Kong, Bermuda, BVI, Cayman, Jersey, Guernsey, Luxembourg, Liechtenstein.
• Most of Latin America: Brazil, Argentina, Mexico, Chile, Colombia, Costa Rica.
• Middle East: UAE, Saudi Arabia, Qatar, Bahrain, Kuwait.
• Asia: Japan, China, Korea, India, Indonesia, Malaysia, Thailand.

Notably NOT in CRS: the United States (uses FATCA bilaterally), Paraguay (preparing), some smaller jurisdictions.

CRS vs FATCA

A US citizen living in France triggers both: CRS (French banks report to France → IRS via FATCA-CRS exchange where treaties allow) AND FATCA (French banks report directly to the IRS via the US-France IGA).

Examples

• French resident opens a Swiss UBS account. UBS asks for tax-residency self-certification. The French address triggers reporting. Each year, UBS reports the account balance + interest + dividends to the Swiss tax authority, which forwards to France's DGFiP via CRS exchange. France matches the data against the resident's tax return.
• US citizen living in Singapore. Singapore is in CRS but US is not. Singapore bank reports the account to Singapore's IRAS, who forwards to other CRS jurisdictions where the US citizen has tax residency (none, since US is not CRS). Separately, FATCA applies directly via the Singapore-US IGA → bank reports the same account to the IRS.

Common mistakes

• Believing CRS doesn't apply to a particular jurisdiction. Even traditional "secrecy" jurisdictions (Switzerland, Singapore, BVI, Cayman) all participate. Genuine non-CRS coverage is now extremely narrow.
• Forgetting passive-NFE lookthrough. A holding company in a CRS jurisdiction with substantial owners (25%+) in another CRS jurisdiction triggers lookthrough reporting on the substantial owner.
• Trusting older "CRS workaround" guides. Many pre-2018 strategies (US LLC structures used to dodge CRS via the US's non-participation) are increasingly closed by enhanced reporting requirements at US banks under FATCA.
• Confusing CRS with FATCA. Different mechanisms, different triggers, both can apply to the same person.