The OECD Common Reporting Standard (“CRS”) obligates Financial Institutions (“FIs”) of over 100 different countries (“jurisdictions”) to report on an annual basis detailed information (both personal & financial information) concerning account holders who have been identified and classified as reportable, with respect to one or multiple jurisdictions.
Similar to the U.S. – Foreign Account Tax Compliance Act (“FATCA”), the objective of the CRS is to reduce tax evasion but differs significantly in scope, as it is a global initiative with fewer exceptions due to minimum account values. FIs are required to capture all tax residency information pertaining to an account holder, rather than just identify US Tax Residency Status. In operational terms, this indicates a significant increase in the volume of required information. In particular, FIs will need to contact almost all their account holders in order to establish and certify the reportable criteria of each account, as well as track, maintain, cleanse and enrich this data before reporting it to the relevant jurisdictions.
In most cases, the tax residency(ies) alone of the account holder(s), will enable the FIs to classify them as either reportable or non-reportable. Therefore, it is expected that most FIs will use CRS Self-Certification forms through which their account holders will declare their tax residencies and other information.