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Zen.com and CRS?

Forester

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May 30, 2021
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It is known that according to the DAC8, the 7th amendment to the Directive on Administrative Cooperation (exactly Council Directive (EU) 2023/2226 of 17 October 2023 amending Directive 2011/16/EU), all EU-operating EMIs are considered Reporting Financial Institutions under CRS effectively onwards 2026-01-01. Reporting will concern all accounts, unless 90-day rolling average balance does not exceed USD 10,000 at any day during the year.
It's the future.

As of now, some EMIs, reportedly, claim not to report; but the vast majority is reticent about this. (Of course, it is recommendable to act as if all report.)

Nevertheless, @Giorgiogori reported here Alternative to blackcatcard about Zen
Zen reports crs .. Confirmed by their customer support.
– I guess that this is perhaps the first case when some EMI openly claims that they report even now.

@Giorgiogori, could you share what the customer support told you exactly?

Or can some other member elaborate on this?

Especially, whether they are reporting everything (as banks generally do) or just the accounts with an average balance over USD 10,000 as it is planned?

I wonder because frankly, I would not expect such activity especially at Zen; if it is all true, I would probably think about possible background, just of my curiosity ;)
 
accounts with an average balance over USD 10,000 as it is planned?
I would like to know who planted the idea that EMIs, banks, and similar institutions only report accounts with a balance over 10K!

Let it be known, this is a huge lie. ALL accounts are reported. I experienced this myself two years ago with the Danish tax authorities who suddenly had access to ALL the EMIs I had opened accounts with, and they were well-informed. Some had only a few euros, others thousands.
 
I doubt any EMI would report CRS if they are not obliged to do so by authorities. It's an additional unnecessary cost for them, especially since EMI sector is so competitive.
Zen Support was lying in my opinion. They won't report until 01/01/2026.
However EMIs with a bank license like N26 and Revolut do report already I believe
 
I would like to know who planted the idea that EMIs, banks, and similar institutions only report accounts with a balance over 10K!

Let it be known, this is a huge lie. ALL accounts are reported. I experienced this myself two years ago with the Danish tax authorities who suddenly had access to ALL the EMIs I had opened accounts with, and they were well-informed. Some had only a few euros, others thousands.
There is a difference between automatic reporting, and reporting on request.
If they request data, of course they will get everything.

And secondly, the tax authorities of some jurisdictions get automatically the data of all the local bank accounts of their residents. This is not even related to CRS.
 
I doubt any EMI would report CRS if they are not obliged to do so by authorities. It's an additional unnecessary cost for them, especially since EMI sector is so competitive.
I understand your perspective; and it makes sense. From another point of view, I can imagine well that it can be a certain tit-for-tat with the regulator...

Zen Support was lying in my opinion. They won't report until 01/01/2026.
Well possible. Then I wonder why and how it exactly looked ;)

However EMIs with a bank license like N26 and Revolut do report already I believe
For sure!

There is a difference between automatic reporting, and reporting on request.
If they request data, of course they will get everything.

And secondly, the tax authorities of some jurisdictions get automatically the data of all the local bank accounts of their residents. This is not even related to CRS.
Exactly.
 
Nevertheless, @Giorgiogori reported here Alternative to blackcatcard about Zen

– I guess that this is perhaps the first case when some EMI openly claims that they report even now.
Maybe the user is lying?

Or Zen thought the Gov is getting in touch? smi(&%

They might be reporting, but as @12345 said, I find it a bit unlikely with the circumstance that there is not yet an enforced necessity for them to do so automatically.
 
I used Zen as a bridge solution for crpyoto exchanger from/to
Yes, this is a very frequent use-case for Zen.

Do you have some experience what their support claim about CRS?
 
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There is a difference between automatic reporting, and reporting on request.
If they request data, of course they will get everything.

And secondly, the tax authorities of some jurisdictions get automatically the data of all the local bank accounts of their residents. This is not even related to CRS.
I completely understand what CRS is about; I'm not new to this. I had a Mister Tango account, and I lived in Denmark. As far as I know, Mister Tango is not located in Denmark! And suddenly, I received a letter from the tax authorities demanding my account statements, and they also needed account statements from Revolut.

So what now? Do you think it's not CRS but perhaps Santa Claus or my neighbor who told them about these accounts?
 
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I completely understand what CRS is about; I'm not new to this. I had a Mister Tango account, and I lived in Denmark. As far as I know, Mister Tango is not located in Denmark! And suddenly, I received a letter from the tax authorities demanding my account statements, and they also needed account statements from Revolut.

So what now? Do you think it's not CRS but perhaps Santa Claus or my neighbor who told them about these accounts?
Yes, it must have been reported based on either CRS (automatic reporting provided your account was subject to it) or EOIR (The exchange of information upon request refers to the exchange of information between tax authorities further to a request for administrative assistance. The basis is formed by bilateral agreements and the administrative assistance convention).

Its worth noting that many countries incl. Lithuania report certain information automatically to local tax office.
Then a request needs to be submitted by foreign authority, and they will quickly get information about the accounts you hold, so they can follow up to get full statements.
 

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