The OECD Implementation Handbook states Financial Institutions should collect and store information and possibly report to their tax authorities for countries that will eventually join the Standard or in case a CAA is concluded at a later date
Such countries which are have not yet joined are those that have signed the Multilateral Tax Convention which is a legal instrument to base CRS Competent Authority Agreements ("CAA").
This means that even though say if you have clients from Kazakhstan with accounts in say Switzerland or Dubai or UK, the Financial Institution maintaining the account (trustee or bank) in Dubai / Switzerland/ UK should collect and store info on Kazakhstan Reportable Person and exchange that data when Kazakhstan joins the CRS.
For example, Kazakhstan signed the Multilateral Tax Convention in 2013 but has not yet commited to the CRS. However, as a signatory to the Convention, it is thus expected to join the CRS like all signatories to the Convention.
|Members of Global Forum on Transparence and Exchange of Information for Tax Purposes but not committed to Common Reporting Standard as at 21 December 2016||Armenia, Azerbaijan, Bahrain, Botswana, Cameroon, Cote d’Avoire, El Salvador, Macedonia, Gabon, Georgia, Guatemala, Jamaica, Kazakhstan, Kenya, Lesotho, Liberia, Mauritania, Niger, Nigeria, Pakistan, Papua New Guinea, Peru, Philippines, Senegal, Tanzania, Tunisia, Uganda, Ukraine, Vanuatu|
|JURISDICTIONS PARTICIPATING IN THE CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS STATUS BUT NOT COMMITTED TO THE COMMON REPORTING STANDARD - 17 DECEMBER 2015||Azerbaijan, Cameroon, EL Salvador, Gabon, Georgia, Guatamala, Kazakhstan, Moldovia,, Morocco, Nigeria, Philippines, Tunisia, Uganda, Ukrain|