Analysis of Common Reporting Standard

The Common Reporting Standard

In July 2014 the OECD published the commentary to the Common Reporting Standards.

The CRS implementation Handbook was released in August 2015.
This website will analyse the CRS and interpret if there are any omissions, lacunae, weaknesses or gaps of the OECD's Common Reporting Standard.

Gaps, omissions
Loopholes, weaknesses
bullet Tax haven can reject agreement with member if subjective concerns regarding confidentiality of data.

bullet Artificial tax residence

bullet Active entities

bullet $250,000 pre-existing entities

bullet FATCA not reciprocal

bullet Non passive income / hard assets

bullet NFE < 2 years / liquidating NFEs



Locations of visitors to this page
bullet3 Non cash value insurance. Note: that irrevocable life investment-linked policies are not exempt from the definition of cash value and hence are in scope.

bullet3 Self certification on residence done once.

bullet3 Non-participating FI only a NFE if it's an investment entity

bullet3 Weak definition of Settlor

bullet3 Personal pensions

bullet3 Entities individually managed, non binding investment mngt - not an investment entity (is a weaker NFE)

bullet3 High threshold of controlling shares (25%) --> weaker beneficiary identification according to management