CRS and cross-border information exchange: what HNW families are reported for, and to where

The Common Reporting Standard (CRS) is the standard for the automatic exchange of financial account information developed by the Organisation for Economic Co-operation and Development (OECD). Financial institutions in participating jurisdictions identify account holders' tax residence, report each year the account information of those who are not local tax residents to the local tax authority, and the tax authority then exchanges it with the tax authority of the account holder's jurisdiction of residence. It is an information-exchange mechanism and does not by itself create a tax liability; whether tax is payable once the information reaches the jurisdiction of residence depends on local tax law and the nature of the income.

How CRS works: identification, self-certification, reporting, exchange

Step 2 is the key. If a self-certification lists several jurisdictions of tax residence, the financial institution may report to each of them. If it lists none, or contradicts information the institution holds (such as address, telephone number or identity documents), the institution must verify further and cannot simply accept it. "Where the report goes" is therefore ultimately decided by actual tax residence, not by where the account is opened, where the assets sit or which passport you hold (the distinction between immigration status and tax residence is explained in residency and tax residence).

Which accounts and policies are reported, and what information

"Financial accounts" under CRS fall mainly into four types.

Each record usually also includes the account holder's name, address, jurisdiction of tax residence, TIN, date of birth and account number. The IRAS CRS e-Tax Guide (fifth edition, 11 August 2026) defines cash value as the greater of the amount the policy owner is entitled to receive on surrender or termination and the amount the policy owner can borrow, and states that CRS provides no US$250,000 exemption threshold for cash value insurance contracts. Pure protection policies without a cash value are generally not financial accounts, subject to the definitions in the e-Tax Guide.

For HNW families, this means private bank custodial accounts, investment-type policies and fund units are essentially all within scope. Switching assets from deposits into policies or funds does not change "whether you are reported"; it only changes the amounts reported and who does the reporting.

Companies, trusts and look-through to controlling persons

Where assets are held in the name of a company or trust, CRS looks not only at the registered holder but at the controlling persons behind it.

1. The entity is classified first: an entity account holder must declare whether it is a financial institution, an active non-financial entity or a passive non-financial entity. An investment entity whose income is mainly from investments and which is managed by a financial institution may itself be a financial institution, with its own due diligence and reporting obligations; holding companies and companies with mainly passive income are usually passive non-financial entities.
2. Passive non-financial entities are looked through to controlling persons: the financial institution must identify the tax residence of the controlling persons and report them; the controlling persons of a company are usually the natural persons with ultimate control.
3. Controlling persons of a trust are defined more widely: they generally include the settlor, trustee, protector (if any), beneficiaries or classes of beneficiaries, and any other natural person exercising ultimate effective control over the trust.

Holding assets through an offshore company or a trust therefore does not make the information "disappear"; the reportable persons simply shift from the registered holder to the controlling persons. Where the trust itself is classified as a financial institution, reporting is carried out on the trustee's side. The CRS classification of a family office entity likewise needs case-by-case assessment; related arrangements are covered in succession and family governance.

Implementation timetable in Singapore, Hong Kong and mainland China

All three are CRS participating jurisdictions. Financial institutions in Singapore and Hong Kong exchange the account information of mainland tax residents with the mainland through their local tax authorities, and vice versa. The current list of partner jurisdictions follows each tax authority's latest publication. Jurisdictions: Singapore / Hong Kong / mainland China.

What amended CRS changes

In 2023 the OECD completed the first comprehensive review of CRS (the IRAS e-Tax Guide refers to "amendments to the CRS as at 8 June 2023", that is, Amended CRS), and at the same time introduced a separate Crypto-Asset Reporting Framework (CARF). According to the IRAS CRS e-Tax Guide (fifth edition, 11 August 2026), the amendments being implemented in Singapore mainly concern two areas:

• Wider scope: from 1 January 2027, institutions that hold Specified Electronic Money Products or central bank digital currencies for customers are also brought within the scope of depository institutions; the amendments also dovetail with CARF to avoid duplicate reporting (the IRAS CRS page also mentions this aim).
• More detailed reporting: institutions must report the role of the reportable person as a controlling person or equity interest holder, whether the account holder and controlling persons have provided a valid self-certification, and the account type, whether it is joint, and whether it is new or pre-existing. For accounts that existed before 1 January 2027, the controlling person's role need not be reported for the 2027 and 2028 reporting years (unless already held in electronic records), and full reporting is required from the 2029 reporting year.

The direct effect on families is that the roles of each party in trust and company structures will be reported more clearly, and the completeness of self-certifications will be recorded separately. Singapore applies the amendments from 1 January 2027, and the first exchanges under the amended rules are expected in 2028 (IRAS, 9 September 2026).

FATCA: an extra layer for US persons

The Foreign Account Tax Compliance Act (FATCA) is a unilateral US law implemented by financial institutions in each jurisdiction through intergovernmental agreements (IGAs). The Model 1 IGA signed by Singapore and the US in 2014 took effect on 18 March 2015, and the reciprocal Model 1 IGA signed in 2018 took effect on 1 January 2021; Reporting SGFIs likewise report to IRAS by 31 May each year (IRAS, 11 August 2026).

Where a family member is a US person, the design of trusts, policies and company structures must also take US reporting into account; see cross-border family questions. Jurisdictions: Singapore / United States.

Self-certification and common misconceptions

A self-certification is a declaration by the account holder to the financial institution. It should reflect actual tax residence and be updated promptly when circumstances change (for example on relocation or a change in tax residence). A false declaration may breach the law of the relevant jurisdictions, and where a financial institution finds inconsistent information, it may treat the account as reportable to several jurisdictions on the basis of the information it holds.

Being reported is not the problem in itself; the risk lies in inconsistency between the information, the facts and your tax filings. Where several jurisdictions of tax residence, trusts or company holdings are involved, seek professional advice in each jurisdiction of tax residence. If you would like this interpreted for your own situation, you can register your enquiry through the contact details on this site.