Tax intelligence

CRS and FATCA: what is actually exchanged, and why opacity is not a strategy

Two regimes, one direction of travel. 126 jurisdictions have signed the CRS multilateral agreement, the United States has signed neither it nor anything like it, and from 2026 crypto joins the system. The honest advice in this section is the whole point of it: there is no hiding place worth building a plan on, and there never was.

Last verified July 2026

What is actually true

  • They are not the same thing and the difference is asymmetry. FATCA is unilateral US law: foreign financial institutions report accounts held by US persons to the IRS, backed by a 30% withholding threat on US-source payments, implemented through roughly 113 intergovernmental agreements. CRS is multilateral and reciprocal: participating jurisdictions collect account data on each other's tax residents and swap it automatically each year.
  • 126 jurisdictions had signed the CRS Multilateral Competent Authority Agreement as at the OECD's 13 March 2025 status list. The United States is not among them, and this is the single most consequential fact in the section. The US receives data on its own taxpayers under FATCA but does not reciprocally report non-US persons' accounts under CRS — which is why 'the US is the world's largest tax haven' has become a defensible claim rather than a provocation. The reciprocity gap is real, but it is a gap in the plumbing, not a licence.
  • Absence from the MCAA does not mean absence from CRS. Hong Kong is a CRS participating jurisdiction that exchanges under bilateral competent authority agreements rather than the multilateral instrument. 'Not on the MCAA list' and 'does not exchange' are different statements, and conflating them has cost people money.
  • Crypto stopped being outside the system on 1 January 2026. The OECD Crypto-Asset Reporting Framework and the amended CRS ('CRS 2.0') both took effect 1 January 2026, with first reports due to national authorities in 2027. CRS 2.0 also pulls in specified electronic money products, central bank digital currencies, and indirect crypto exposure held through derivatives and investment vehicles.
  • CARF commitments, per the OECD Global Forum's list last updated 23 June 2026: 46 jurisdictions undertaking first exchanges by 2027 (including the UK, all EU Member States listed, Cayman Islands, Guernsey, Jersey, Isle of Man, Liechtenstein, Japan, Brazil, South Africa); 29 by 2028 (including Switzerland, Singapore, Hong Kong, UAE, Bahamas, Bermuda, BVI, Panama, Canada, Australia, Cyprus, Mauritius, Seychelles, Thailand); and exactly one by 2029 — the United States. Five jurisdictions the Global Forum identifies as CARF-relevant have not committed: Argentina, El Salvador, Georgia, India and Viet Nam.
  • The honest statement: opacity is not a strategy and never was. Every structure that depended on the account not being seen has been dismantled — by CRS from 2017, by beneficial ownership registers, by economic substance rules, and now by CARF. What survives is not concealment but substance: actually living where you say you live, actually paying what is due there, and actually having a reason for the structure beyond invisibility. The jurisdictions that still do not exchange are, without exception, places no UHNW family would custody serious assets. That is not a coincidence — it is the trade the system was designed to force.

Jurisdiction by jurisdiction

United States medium
Not a CRS MCAA signatory — the only major financial centre outside the multilateral system. Receives data on US persons under FATCA via roughly 113 IGAs; reciprocal reporting on non-US persons is limited and IGA-dependent. Committed to CARF first exchanges by 2029, later than every other committed jurisdiction. The asymmetry is genuine; treating it as a plan is not, because the US is not a jurisdiction where a non-US family can be tax-resident without becoming a US taxpayer on worldwide income.
Hong Kong low
A CRS participating jurisdiction that exchanges under bilateral competent authority agreements rather than the multilateral MCAA, so it does not appear on the MCAA signatory list. Committed to CARF first exchanges by 2028. A worked example of why 'not on the list' must never be read as 'does not exchange'.
Georgia medium
A CRS MCAA signatory, but one of only five jurisdictions the Global Forum identifies as CARF-relevant that have NOT committed to implement CARF (with Argentina, El Salvador, India and Viet Nam). Relevant given Georgia's popularity for crypto-holding residents — and a gap that is far more likely to close than to widen.
Switzerland, Singapore, UAE low
All CRS MCAA signatories, all exchanging, all committed to CARF first exchanges by 2028. The historical association of any of the three with banking secrecy is 15 years out of date and should be treated as a reputational liability in a residency dispute rather than an asset.
Cayman Islands, Guernsey, Jersey, Isle of Man low
CRS signatories and in the leading CARF group — first exchanges by 2027, ahead of Switzerland, Singapore and the UAE. The offshore centres most associated with secrecy in the public imagination are now among the earliest and most complete implementers, precisely because their business model depends on not being blacklisted.
What can go wrong
  • CRS reports tax residence as you self-certify it. Certifying a residence that your facts do not support is a false self-certification — a criminal offence in many jurisdictions and the fastest route from a tax question to a criminal one.
  • A CRS report is not an assessment; it is a lead. The data arrives at your home revenue authority, gets matched, and generates an enquiry. The gap between the report and the enquiry is measured in years, which is why people mistake silence for safety.
  • Controlling person reporting looks through structures. Trusts, foundations and passive holding companies are reported with settlors, protectors, beneficiaries and controlling persons named. The entity does not obscure the individual; it merely adds a line to the form.
  • Crypto exchanges are reporting from 1 January 2026 with first exchanges in 2027 — retrospective in effect, because the 2026 data being reported in 2027 is already being collected now. Anyone assuming a further grace period is a year late.
  • Multiple tax residences reported simultaneously is a red flag, not a hedge. Two jurisdictions each receiving a self-certification naming the other is the classic profile that triggers both.
  • The remaining non-exchanging jurisdictions are non-exchanging because nobody credible banks there. That is the reason, not an oversight, and it will not be fixed in your favour.
Sources (6)