CRS question (can anyone even reliably answer this?)

[dreadpiraterob]

Can a country that participates in CRS send a specific request to obtain information on someone that is resident in their country BUT has a foreign passport ( also CRS country) AND reported his passport country as residence to banks?

 

[Sols]

CRS does not contain provisions for requesting information. The information is automatically shared.

However, there are still TIEAs (Tax Information Exchange Agreements) in place under which countries can send requests for information to other countries. These requests have no restrictions as such but must be substantiated.

So in your example, reporting can be done automatically to both the country of citizenship and the country of residence although it is normally just the country of residence. Additionally, if there is a TIEA or similar agreement in place, a request can be sent at any time about you.