CRS-2025 data exchange: Which countries share data and where privacy is still maintained

CRS-2025 data exchange: Which countries share data and where privacy is still maintained

The CRS-2025 data exchange is a system for the automatic exchange of financial information covering over 120 jurisdictions. Banks, brokers, funds, and licensed financial institutions are required to submit reports on non-resident accounts to their tax authorities, and these authorities, in turn, to the tax authorities of the clients' countries of residence.

The use of international structures, bank accounts, holdings, and investment companies requires a clear understanding of which countries participate in the CRS, which countries introduce extended reporting forms, and where confidentiality still applies.

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Who is participating in CRS in 2025?

By the end of 2025, CRS will be operational in virtually all developed and most developing countries.
The system includes:

1. all EU countries (Spain, Portugal, France, Germany, Cyprus, Ireland, etc.);
2. United Kingdom (despite Brexit);
3. Switzerland — with expanded audit standards and FATF requirements;
4. United Arab Emirates — CRS is fully implemented, exchange has been active since 2019;
5. Singapore and Hong Kong — participate in and strengthen AML supervision;
6. Canada, Australia, New Zealand;
7. South American countries, including Mexico, Colombia, Argentina, Brazil.

The OECD is expanding the list of requirements to include:

1. flags of suspicious structures;
2. control of offshore holdings;
3. Strengthening reporting on trusts and private foundations.

What exactly is transmitted in the CRS report?

The following items are included in the automatic exchange:

1. owner details (full name, address, tax identification number - TIN);
2. invoice number and product type;
3. balance as of December 31;
4. all accrued interest, dividends, income from the sale of assets;
5. identification of controlling persons of companies, holdings and trusts.

Financial institutions are required to apply KYC, AML, AEOI due diligence , including checks of beneficial owners (UBO) and controlling persons.

Countries that Maintain Privacy (2025)

Important: We are not talking about countries that allow asset concealment , but about jurisdictions that do not participate in the CRS but still have independent financial systems.

By 2025, the number of such countries has been significantly reduced , but the following remain formally outside the CRS:

1. Belize - no automatic exchange;
2. Mongolia — participation is postponed;
3. Maldives — CRS is not implemented;
4. Cambodia — no AEOI mechanism;
5. The Dominican Republic — exchange is limited;
6. Nicaragua - there is no regular exchange;
7. Bolivia — there is no CRS infrastructure.

Some countries participate partially or only unilaterally:

1. Panama — CRS is implemented, but with limited transmission;
2. Paraguay - unilateral agreements, not in all directions;
3. Georgia — exchange is carried out, but selectively and upon request.

It is legally important to understand:
✔ countries without CRS do not remove the obligation to declare income in the country of tax residence;
✔ confidentiality ≠ protection from tax liabilities;
✔ Banking compliance in such countries will still retain strict AML filters in 2025.

Why Privacy is Declining

Even jurisdictions outside the CRS are strengthening regulation along the lines of:

1. Fatf-recommendations;
2. requirements for beneficiaries (UBO);
3. AML checks when opening accounts;
4. restrictions on corporate structures without substance.

Even if the country is formally outside the CRS, banks require:

1. proof of income;
2. tax number;
3. declarations of residence;
4. business model and documentation on the origin of funds.

By 2025, large banks had virtually eliminated the possibility of servicing structures without transparency.

We offer a solution at the level of international standards

How CRS-2025 affects international structures

Companies in the UAE, Switzerland, Singapore, Hong Kong, the EU, and the UK are required to provide information on:

1. controlling persons,
2. UBO,
3. financial flows,
4. account balances.

Trust and holding structures no longer provide privacy.
Without an update, the model risks falling under:

1. fines for failure to declare;
2. revision of tax status;
3. additional charges in the EU;
4. Automatic requests as part of AML checks.

In which countries is regulated privacy still possible?

Legally correct options exist if required:

1. protection of private information;
2. asset structuring;
3. investment ownership;
4. protection of family and capital.

In 2025, smart privacy models ensure:

✔ United Arab Emirates

There is a CRS, but corporate information is disclosed to a limited extent if the structure is built correctly:
— holding + free business zone
— substance
— local reporting without a public UBO registry

✔ Singapore

CRS works, but client privacy is protected by strong banking regulations.

✔ Qatar and Bahrain

There is reporting, but individual information is only available to the regulator.

✔ Switzerland (post-2023)

The CRS is full, but there are no publicly available registries UBO no.
Legally transparent structures remain confidential.

These are legal structuring options, not concealment models.

Which tools require the most attention in 2025?

1. accounts of companies without substance;
2. offshore holdings with nominee directors;
3. trusts without transparent reporting;
4. accounts in countries planning to join the CRS in 2026–2027.

All such structures require:

1. updating corporate documentation;
2. monitoring CRS obligations;
3. correct declaration in the country of tax residence.

What does Jurisprudential Consulting Group do?

We work with clients from the EU, UK, Switzerland, UAE and Asia.

Сonclusion

CRS-2025 data exchange — is a nearly global system for exchanging financial information.
Most countries participate in automatic exchange, and privacy is only possible within the framework legal, transparent and properly structured structures.
We will assess your structure, check CRS risks, and propose a secure strategy for asset ownership and international business.