CRS and FATCA Explained: What Every Expat Needs to Know

Offshore financial privacy — the ability to hold money in foreign accounts without your home country's tax authority knowing — has largely ceased to exist. Two frameworks have fundamentally changed the landscape: the US Foreign Account Tax Compliance Act (FATCA) and the OECD's Common Reporting Standard (CRS). Together, they create near-universal automatic exchange of financial account information between tax authorities worldwide. For expats and internationally mobile investors, understanding these systems is essential — not to evade them, but to ensure you are meeting your disclosure obligations and are not caught out by inadvertent non-compliance.

What Is FATCA?

FATCA was enacted by the United States Congress in 2010 and came into effect in 2014. Its primary purpose is to prevent US citizens and US tax residents from using offshore accounts to evade US tax.

Under FATCA, foreign financial institutions (FFIs) — banks, investment platforms, insurance companies, and others — must identify accounts held by US persons (US citizens, US tax residents, and certain US-connected entities) and report account details to the US Internal Revenue Service (IRS). Institutions that refuse to comply face a 30% withholding tax on certain US-sourced payments.

The US has entered into Intergovernmental Agreements (IGAs) with over 110 countries to facilitate FATCA compliance. Most countries, including the UK and the major financial centres used by expats (UAE, Cyprus, Singapore, Channel Islands, Isle of Man), have IGAs in place. This means your bank in Dubai, your pension provider in Gibraltar, or your investment account in Singapore is legally obliged to identify whether you are a US person and, if so, report your account to the relevant local tax authority, which in turn shares the information with the IRS.

Who does FATCA affect?

FATCA catches a much wider group than many US persons realise:

• US citizens living anywhere in the world (the US taxes on citizenship, not residency)
• US Green Card holders
• People who meet the "substantial presence test" for US tax residency
• Certain entities with US beneficial owners

US persons with foreign financial assets exceeding $50,000 (individual) or $100,000 (married filing jointly) at year-end, or $75,000 / $150,000 at any point during the year, must file IRS Form 8938. This is separate from the FBAR (FinCEN Form 114) requirement, which requires reporting of foreign accounts exceeding $10,000 in aggregate value.

What Is the Common Reporting Standard?

CRS is the OECD's global standard for automatic exchange of financial account information, adopted by over 100 jurisdictions. Whereas FATCA targets US persons, CRS covers tax residents of all participating countries.

Under CRS, financial institutions in participating countries must:

1. Identify the tax residency of all account holders (through self-certification and due diligence)
2. Collect relevant account information (balances, income paid, proceeds from disposals)
3. Report this information to their domestic tax authority
4. The domestic tax authority automatically exchanges the information with the tax authority of the account holder's country of tax residence

Example: A British national living in the UAE who holds an investment account in the Isle of Man will have their account information reported by the Isle of Man financial institution to the Isle of Man tax authority, which will exchange it with the UAE Federal Tax Authority (FTA) — or, if they are actually UK tax resident, with HMRC.

Which countries participate in CRS?

As of 2026, over 110 jurisdictions participate in CRS, including all EU member states, the UK, Australia, Canada, the UAE, Singapore, Hong Kong, Switzerland, the Cayman Islands, the British Virgin Islands, Jersey, Guernsey, Isle of Man, Cyprus, Malta, and many others. Notably, the United States does not participate in CRS (it has its own FATCA system instead).

What Information Gets Reported?

Under both FATCA and CRS, the information reported typically includes:

• Account holder name, address, tax identification number(s), and date of birth
• Account number and financial institution details
• Account balance at year-end
• Gross interest, dividends, and other income credited to the account during the year
• Gross proceeds from disposal of financial assets (in certain jurisdictions)

The scope has been expanding. A 2023 OECD extension (the Crypto-Asset Reporting Framework, or CARF) extends CRS-style reporting to crypto asset service providers. Many jurisdictions are implementing CARF from 2026 or 2027.

How Self-Certification Works

When you open a new account at a financial institution in a CRS-participating jurisdiction, you will typically be asked to complete a self-certification form declaring your tax residency. You must provide your tax identification number(s) for each country of tax residence.

Providing false information on a self-certification form is tax evasion. Financial institutions are required to apply due diligence to certifications and may reject implausible claims.

If your tax residency changes — you move countries — you should notify your financial institutions so they can update their records and report to the correct jurisdiction. Failure to notify can result in reporting to the wrong jurisdiction, which may in turn create compliance issues.

Implications for Expats

For expats living abroad, CRS and FATCA have several important implications:

All your accounts are visible. The days of quietly accumulating offshore accounts without your home country's knowledge are over for most people. Both the country you moved from and the country you moved to may receive reports about your accounts.

Tax residency status matters enormously. Where your account information is reported depends on where you are tax resident. This is not simply where you live — it is determined by national tax residence rules (including, for the UK, the Statutory Residence Test). If you are uncertain whether you have cleanly broken UK tax residency, take professional advice.

Historic non-disclosure carries penalties. HMRC operates the Worldwide Disclosure Facility (WDF) for voluntarily disclosing previously undisclosed overseas income and gains. Penalties for voluntary disclosure are lower than for amounts discovered through CRS/FATCA reporting. If you have any doubt about past compliance, seek advice proactively.

US persons face particular complexity. The combination of FATCA, FBAR, Form 8938, and the US's worldwide taxation on citizens means US nationals living abroad face significant ongoing compliance costs. Some financial institutions in non-US jurisdictions decline to open accounts for US persons precisely because of the compliance burden FATCA imposes on them.

Common Misconceptions

"CRS only catches deliberate tax evaders." Not true. CRS catches everyone with foreign accounts in their country of tax residence — including entirely compliant taxpayers. The issue is not whether your tax is paid, but whether your tax returns disclose your foreign accounts and income.

"If I'm non-dom, I don't need to worry." The remittance basis for non-domiciled individuals was abolished from 6 April 2025. It has been replaced by the four-year Foreign Income and Gains (FIG) regime for individuals who have not been UK-resident in the prior 10 years. Even under the FIG regime, CRS reporting is unaffected — foreign accounts in CRS-participating jurisdictions are still reported to HMRC regardless of whether the income or gains are exempt under FIG. Whether UK tax is owed depends on your specific position, but HMRC will receive the information either way.

"Crypto is not covered." As noted above, CARF extends reporting to crypto assets. Many platforms are already collecting tax residency information in preparation for reporting obligations.

"The UAE doesn't tax, so CRS doesn't matter there." UAE residents are still subject to CRS reporting — information about their accounts in CRS-participating jurisdictions is exchanged with the UAE FTA, which may in turn share it with the country of previous tax residence if that country has requested exchange. The UAE's CRS obligations are real and enforced.

Staying Compliant

The good news is that CRS and FATCA are not difficult to comply with if you are meeting your existing tax obligations:

1. Ensure your tax returns in each country of residence disclose all foreign income and gains
2. Keep accurate records of which accounts you hold, where, and what income and proceeds they generate
3. When completing self-certification forms, be accurate about your tax residency
4. If your tax residency changes, notify your financial institutions promptly
5. If you are a US person, ensure you are meeting FBAR, Form 8938, and any other US overseas reporting obligations — these apply regardless of whether you owe any US tax
6. If you have any legacy compliance issues, take proactive steps to disclose them before they are discovered

How Global Investments Can Help

At Global Investments, we advise internationally mobile clients on the practical financial planning implications of CRS and FATCA. Whether you are structuring a new investment portfolio across multiple jurisdictions, reviewing the compliance of your existing accounts, or trying to understand how a change in tax residency affects your reporting obligations, our advisers can help — and can connect you with specialist tax lawyers for formal disclosure programmes where needed. We work with clients across the UK, UAE, Cyprus, Spain, Thailand, Greece, and Egypt.

This article is for general information only and does not constitute tax advice. CRS and FATCA rules are complex, change frequently, and apply differently depending on individual circumstances. Always seek qualified professional advice. Penalties for non-compliance can be severe.