EMI CRS reporting variances

[Cavendish]

Hi, as a new member I would just like to say thank you. I'm a numbers and process person so this forum makes for perfect reading! My initial question relates to EMI's and the well discussed CRS regs. Is it known exactly what each EMI reports on? For example, some say end of year balance, some highlight largeish transfers through the reporting period, and some may not report at all unless asked? I don't know, these are purely observational possibilities. My motivation to understand is one where future surprises are kept to a minimum! Any knowledge would also obviously help future EMI choices. Would large amounts in an EMI that is in a different country to your residency spark alarm bells? - or is it actually a perfect world CRS scenario where every EMI happily sends off the required info with your TIN at end of year?.. Thanks again

 

[JustAnotherNomad]

The CRS spec is public, you can easily find it on the internet. Not all EMIs fall under CRS. In general, I wouldn't build a structure that relies on some entity not reporting, it's a huge risk. Better to stay legal.

 

[legrant]

In order to find what's usually reported you could've looked at a few other threads as it's been asked before.

According to HSBC, they're reporting the following (I assume most banks report the same thing):

• the balance or value
• the total amounts of interest or payments credited

If taxman wants more information though, they will either ask you or the bank directly.

Some banks may report more things, but it's hard to know unless you work at the bank in that specific area. Large transactions don't really have to appear on the CRS report, if they're large and sketchy, the bank itself will look into it and may freeze your account, ask you questions and maybe report the incident to the taxman in your country.


"Would large amounts in an EMI that is in a different country to your residency spark alarm bells?"

If you're using an EMI in your own country, you're pretty much done. If you use an EMI from another country, it depends on if it's doing CRS reporting, if they are, you're done if the amounts are large. If you have low amounts (5-20k) I doubt it'll be an issue (from personal experience), however, you may face trouble in the future.

As the user above said, don't build a structure based on what an EMI does or doesn't do today, they may start reporting tomorrow, in a week, in a month, no one knows. If you're dealing with very large amounts, move to a 0% income tax country or a country with a territorial tax system and you should be fine and your money will be legal.

 

[Cavendish]

In order to find what's usually reported you could've looked at a few other threads as it's been asked before.



Some banks may report more things, but it's hard to know unless you work at the bank in that specific area. Large transactions don't really have to appear on the CRS report, if they're large and sketchy, the bank itself will look into it and may freeze your account, ask you questions and maybe report the incident to the taxman in your country.


"Would large amounts in an EMI that is in a different country to your residency spark alarm bells?"

If you're using an EMI in your own country, you're pretty much done. If you use an EMI from another country, it depends on if it's doing CRS reporting, if they are, you're done if the amounts are large. If you have low amounts (5-20k) I doubt it'll be an issue (from personal experience), however, you may face trouble in the future.

As the user above said, don't build a structure based on what an EMI does or doesn't do today, they may start reporting tomorrow, in a week, in a month, no one knows. If you're dealing with very large amounts, move to a 0% income tax country or a country with a territorial tax system and you should be fine and your money will be legal.

Thank you for your response, much appreciated.

 

[legrant]

Thank you for your response, much appreciated.

"If you use an EMI from another country, it depends on if it's doing CRS reporting, if they are, you're done if the amounts are large"

I want to correct myself. When I say "if the amounts are large", I'm talking about the amount being held in the account, not the transactions being made. The transactions being made will only affect you if the EMI/Bank thinks they're sketchy as transactions are not usually reported under CRS, however, if taxman gets the CRS report and then ask for transactions and find large ones, that'll be another problem you'll have to deal with.

 

[Cavendish]

"If you use an EMI from another country, it depends on if it's doing CRS reporting, if they are, you're done if the amounts are large"

I want to correct myself. When I say "if the amounts are large", I'm talking about the amount being held in the account, not the transactions being made. The transactions being made will only affect you if the EMI/Bank thinks they're sketchy as transactions are not usually reported under CRS, however, if taxman gets the CRS report and then ask for transactions and find large ones, that'll be another problem you'll have to deal with.

Thanks again. There won't be any substantial funds held in the accounts, they are purely used for bridging purposes between various destinations. Funds all legit and small fry to be honest but was just concerned if a transaction ended up being counted several times! As an example - Revolut got very excited even though i provided the appropriate documentary evidence. They are useful for free domestic FX swaps but to be honest I am preferring to trade a "free" service for a "pay and receive quality" service!