CRS and FATCA reporting: what company owners should know

A generation ago, an account held by a company in another country was often invisible to its owner’s home tax authority. Today, it almost certainly is not. Two regimes, the OECD’s Common Reporting Standard and the United States’ FATCA, mean that financial institutions across the world report accounts held by companies, and by the individuals behind them, to tax authorities as a matter of routine.

AT Express is headquartered in Cyprus, with offices in the United Kingdom, Hong Kong, China, Vietnam and Singapore. Every structure we help to establish is designed on the assumption that it will be reported, and this article explains how.

The Common Reporting Standard

The Common Reporting Standard, or CRS, was developed by the OECD as part of its international standards on tax transparency. Participating jurisdictions require their financial institutions, including banks, custodians, certain investment entities and some insurers, to identify the tax residence of their account holders and report accounts held by residents of other participating jurisdictions. Each year, the information is sent to the local tax authority and exchanged automatically with the authorities of the countries concerned.

Within the European Union, the CRS is implemented through the Directive on administrative cooperation, which has been extended over time to cover further categories of information. Implementation and effectiveness are peer-reviewed by the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes.

What is reported

For each reportable account, institutions generally report the account holder’s name, address, tax residence and tax identification number, the account number, the balance or value at the end of the year, and income such as interest and dividends, together with gross proceeds from sales of financial assets.

For companies, a crucial distinction is between active and passive entities. Where a company is passive, broadly one whose income is mainly investment income, the institution must also identify its controlling persons, the individuals who ultimately own or control it, and report them where they are resident in another participating jurisdiction. Many holding companies and investment vehicles fall into this category. In practice, an owner’s home tax authority will often learn not only that the company exists, but how much it holds.

The self-certification forms banks ask for are part of every application we prepare; see our page on international bank account opening.

FATCA

The Foreign Account Tax Compliance Act is a US law, administered by the Internal Revenue Service, that requires foreign financial institutions to report accounts held by US persons, and by entities with substantial US owners, to the IRS. Many countries have signed intergovernmental agreements under which their institutions report through the local tax authority. Institutions that do not comply face US withholding on certain payments, which is why FATCA reaches almost every bank in the world.

The United States does not participate in the CRS. Owners with US connections should therefore consider both regimes, and our guide to the Delaware LLC for non-residents covers the US side for company owners.

Self-certification

When opening an account, a company completes a self-certification stating its tax residence, its CRS and FATCA classification and, where relevant, details of its controlling persons. US tax forms, such as the W-8 series, may also be required. The bank is entitled to challenge a certification that is inconsistent with what it knows, and providing false information can be an offence. Accuracy here protects everyone.

Crypto-assets and the next phase

Transparency standards continue to widen. The OECD has developed a Crypto-Asset Reporting Framework, designed to bring exchanges of information on crypto-assets broadly into line with the CRS, and tax authorities in many jurisdictions, including the Cayman Islands Department for International Tax Cooperation, now list it among the frameworks they administer. Owners whose companies hold or trade crypto-assets should assume that these holdings, too, will become visible to the tax authorities of their country of residence, and should keep records accordingly.

The direction of travel is consistent: more categories of information, exchanged more often, between more countries. A structure designed today should be robust against the reporting rules of tomorrow, not merely those in force now.

What it means in practice

• Assume that accounts held by your companies will be reported to your country of tax residence.
• Make sure the structure is declared in your own tax returns, including any controlled foreign company income.
• Keep the company’s classification under review as its activities change.
• Update your bank promptly if you change your residence.

None of this makes international structures less useful. It makes it essential that they are commercially sound and properly declared. Our page on international tax planning explains how we coordinate advice, and our article on economic substance covers the parallel rules on real activity.

For jurisdiction-specific detail, see our pages on the British Virgin Islands, Singapore and Cyprus, or the overview on our corporate services page.

If you would like to talk through how this applies to your own plans, our team would be glad to help. You can call +357 979 42 388, message us on WhatsApp or write to us through our contact page.

Sources

• OECD: International standards on tax transparency, including the Common Reporting Standard
• European Commission: Directive on administrative cooperation (DAC)
• OECD: Global Forum on Transparency and Exchange of Information for Tax Purposes
• Internal Revenue Service: Foreign Account Tax Compliance Act (FATCA)
• Cayman Islands Department for International Tax Cooperation: Economic substance

This article is for general information only and does not constitute legal, tax or financial advice. Company formations and bank accounts are subject to know-your-customer (KYC) and anti-money-laundering (AML) checks, and no outcome or timescale can be promised. Companies may be subject to economic substance rules, and accounts and their owners may be reported to tax authorities under the OECD Common Reporting Standard (CRS) and FATCA. Check the current EU list of non-cooperative jurisdictions for tax purposes and take independent advice in each country concerned. Figures are stated as at October 2026 and may change. AT Express is a private consultancy and is not affiliated with any government, registry or bank.

Featured image: “Sihl Valley and Lake Zurich” by Daniel Kraft, licensed under CC BY-SA 3.0.