Tax
CRS (Common Reporting Standard)
Also known as: Common Reporting Standard, OECD CRS, Automatic Exchange of Information
CRS (Common Reporting Standard) was developed by the OECD on the model of FATCA and adopted in 2014. As of 2026, more than 120 jurisdictions participate, including all EU states, the UK, Switzerland, Singapore, Hong Kong, Australia, Canada, Japan, the UAE, and most major financial centres. Participating financial institutions identify account holders' countries of tax residence (using self-certification at account opening plus electronic indicia like residence address, phone numbers, and standing instructions) and report account data annually to their local tax authority, which then forwards it to the holder's country-of-residence tax authority via secure exchange.
Reportable financial-institution data includes: account holder name and address; tax-residence country; tax identification number (TIN); account number and type; year-end account balance; gross interest, dividends, and proceeds from financial-asset sales; and for trusts and foundations, controlling-person information.
For US expats, the practical interaction is asymmetric. The US itself does NOT participate in CRS — instead it operates the parallel FATCA bilateral framework. So an American living in Germany has German bank data reported to the IRS via FATCA, but US bank data is NOT automatically reported to German authorities via CRS. The US has signed FATCA Inter-Governmental Agreements (IGAs) with most CRS jurisdictions, of which the Model 1 IGAs include reciprocity in principle but with FATCA-narrower reporting in practice. This asymmetry is a long-standing critique of US tax-transparency policy.
For non-US expats (a German tax resident in Portugal, a Brit in Spain, etc.), CRS means that their home-country tax authority receives full bank-by-bank account data automatically. There is no "hidden" foreign account in any CRS-participating jurisdiction. Combined with EU AML directives requiring beneficial-owner registries, the era of pre-FATCA financial opacity is effectively over for retail expat banking.
Sources
Last factual review: 2026-05-08.
Related terms
FATCA
FATCA is a 2010 US law requiring foreign financial institutions to report accounts held by US persons to the IRS, and US persons themselves to disclose foreign financial assets above threshold amounts on Form 8938. Thresholds for individuals living abroad start at $200,000 (single) / $400,000 (joint) at year-end. FATCA penalties for non-disclosure are severe: $10,000 minimum per failure, doubling every 30 days up to $50,000.
FBAR
FBAR is the Foreign Bank Account Report (FinCEN Form 114) that US persons file annually if the aggregate value of their foreign financial accounts exceeded $10,000 at any point during the year. Filed electronically with the Treasury Department's FinCEN (not the IRS), separate from Form 1040. Penalties for wilful non-filing can reach 50% of the account balance per year. Due date: 15 April with automatic 6-month extension.
Tax Residency
Tax residency determines which country has primary right to tax your worldwide income. Each country sets its own tests — typically based on physical presence (often 183+ days/year), domicile, primary economic interests, or family ties. Holding a residence permit does not automatically establish tax residency, and tax residency does not require a residence permit. Dual tax residency is resolved by tax-treaty tie-breaker rules.
Tax Treaty
A tax treaty is a bilateral agreement between two countries that allocates taxing rights over cross-border income, prevents double taxation, and provides mechanisms to resolve disputes. Treaties typically follow the OECD or UN Model Convention. The US has tax treaties with about 70 countries; the UK with about 130. Treaty benefits often require formal claim on a tax return (e.g., IRS Form 8833 for treaty-based positions on a US return).