Protected Cells

Protected Cells are not a solution for CRS

The reportable persons of a PCC will be as per Guernsey registry FAQ 5

a PCC consists of a core and of separate and distinct cells. The assets and liabilities of one cell are segregated and protected from those of the other cells. Similarly, the assets and liabilities of the core are segregated and protected from those of the cells. Key Features of a PCC

The principle is that where any liability arises which is attributable to a particular cell or to the core, the cellular assets attributable to that cell or the core assets attributable to the core, should be used in satisfaction of the liability. Thus, when considering a liability attributable to a cell, the core assets and the assets attributable to any cell other than the cell to which the relevant liability is attributable, are “protected assets”.
If PCC is a Passive NFE - Who are Controlling Persons

If PCC is an Investment Entity - Who has Equity Interest