We have spoken about nominees before – https://htj.tax/2024/12/can-i-use-nominees-to-avoid-crs-and-carf/
We have spoken about companies limited by guarantees – https://htj.tax/2024/12/using-companies-limited-by-guarantees-to-circumvent-crs-or-carf/
Other Ways of Misinterpreting CRS
- Zero cash value insurance – Some proponents of zero cash value Private Placement Life Insurance policies (PPLI) mistakenly believe these are out of scope of CRS due to not being a cash value financial asset. The CRS update clearly states that where access to the assets have voluntarily been surrendered and no-one has access to the assets except beneficiaries upon death of life assured, the reportable account holder is the policyholder.
- Nil report on Singapore irrevocable trusts – Singapore has recently drooped the nil report guidance and states the reportable amount should be according to the CRS rules and implementation handbook.
- Fake Active NFEs – certain banks often categorise passive NFEs as non-reportable Active NFEs if the customer claims the accumulated cash is for the purpose of business. However, the OECD FAQ reminds Fis that cash is regarded counting towards a Passive NFE whether the cash generates passive income (interest) or not.
- Broad participation retirement plans – Some countries aid in individual managed savings plans in group pensions which can be paid out at any age, to be categorised as non-reportable pensions legislating that such plans will be untaxed and reported locally.
