9 Countries that do not participate in the automatic exchange of information (CRS)

9 Countries that do not participate in the automatic exchange of information (CRS)

Table of Contents

Foreword

In this article, you can find out which countries will not be participating in the automatic exchange of information (CRS) in 2024. You will find a list of countries without CRS, as well as countries that do not participate in the CRS. If you are looking for a foreign account without information exchange, this article provides you with up-to-date information on CRS-free countries in 2024 with banks that maintain discretion.

In today's globalized world, banks, brokers and internet platforms such as Airbnb are increasingly interested in where their customers are liable to pay tax. The reason for this is the Common Reporting Standard (CRS), also known as the automatic exchange of information, which about 5 years ago from the OECD was introduced. Almost all major countries participate in the CRS, but there are some exceptions, which are discussed in more detail in this article.

How does the CRS (AEOI - automatic exchange of information) work?

The CRS (Common Reporting Standard) obliges banks and financial institutions to collect financial information on account holders and beneficiaries. This data is then transmitted to the clients' countries of residence as part of the automatic exchange of information. The main aim of the CRS is to combat tax evasion.

To date, 111 countries and territories have joined the CRSincluding most tax havens and Offshore banking havens. The majority of these countries are already actively exchanging data. When opening an account, banks must now explicitly ask their customers where they are resident for tax purposes. The answer "everywhere and nowhere" is no longer accepted.

The CRS status today - 2024 (CRS participants / List of countries 2025)

According to the OECD, 111 countries and territories participate in the automatic exchange of information. These include many well-known tax havens such as:

  • Bahamas
  • Cayman Islands
  • Cyprus
  • Hong Kong
  • Monaco
  • Liechtenstein
  • Panama
  • Switzerland
  • United Arab Emirates
  • Vanuatu

The list includes the entire European Union, almost all countries of citizenship and investment, most of the developed world and most of the places where most people would like to open an account and bank.

 

Top non-CRS countries with good banks / banking options (Updated September 17, 2024)

Top 9 countries that offer good banking options and do not participate in the CRS:

  1. Armenia
  2. Botswana
  3. Dominican Republic
  4. Georgia
  5. Guatemala
  6. Cambodia
  7. North Macedonia
  8. Philippines
  9. United States

What are the banking advantages in Armenia?

  • Emerging financial center without CRS
  • Simple account opening process
  • Banks like Ameriabank and Evocabank offer excellent customer experience
  • High interest rates for local currency
  • Options for Western and Eastern currencies

Why is Botswana a good banking destination?

  • One of the most stable countries in Africa
  • Least indebted African country with high foreign exchange reserves
  • Well-developed infrastructure and low crime rate
  • English as an official language
  • Presence of large banks such as Standard Chartered and Absa
  • Account opening possible in about one week

What makes the Dominican Republic attractive for banking transactions?

  • Popular expat destination with options for permanent residence permits
  • Several banks and savings banks, mostly locally owned
  • Presence of international banks such as Scotia Bank

What makes Georgia stand out in banking services?

  • One of the easiest places to open an account, even for non-residents
  • Top banks are TBC and Bank of Georgia
  • Note: Georgia became a CRS participant in 2023

What should you know about banking in Guatemala?

  • Often overlooked expat location
  • Local banks such as Agromercantil and Azteca Bank dominate the market
  • International banks such as Citibank are also represented
  • Caution due to banks' holdings of mediocre government bonds

Why should you consider Cambodia for banking?

  • One of the last truly favorable countries
  • Strong economic growth since the 1990s
  • Presence of local and international banks, including Malaysian banks
  • High interest rates for US dollar accounts
  • A business visa may be required to open an account

What makes North Macedonia attractive for banking transactions?

  • One of the most business-friendly countries in the Balkans and Europe
  • Low flat-rate tax rates and incentives for companies
  • Improving banking system
  • Local banks owned by major European banks such as Société Générale, Erste Group and ProCredit Bank

How does the Philippines perform when it comes to banking options?

  • Popular expat destination with easy account opening
  • Presence of international and strong local banks
  • Appropriate interest rates
  • FATCA-compliant banks
  • Large banks such as HSBC and local banks such as Metrobank available

Why is the USA mentioned as a non-CRS banking option?

  • United States is not a CRS participant, despite the introduction of FATCA (concerns only private accounts and is therefore not relevant for US LLCs and business accounts of foreign citizens)
  • Exchanges some information, but on its own terms
  • Known as one of the largest tax havens in the world, especially countries such as Delaware
  • Significant amount of global "hot money" at American banks

Which countries do not participate in the CRS?

Complete list of non-CRS countries 2024, by region

Status: June 13, 2024

Africa

  1. Ethiopia
  2. Benin
  3. Burkina Faso
  4. Burundi
  5. Democratic Republic of the Congo
  6. Djibouti
  7. Eritrea
  8. Gabon
  9. Gambia
  10. Guinea
  11. Guinea-Bissau
  12. Cameroon
  13. Comoros
  14. Congo
  15. Liberia
  16. Libya
  17. Madagascar
  18. Malawi
  19. Mali
  20. Mauritania
  21. Mozambique
  22. Namibia
  23. Niger
  24. Rwanda
  25. São Tomé and Príncipe
  26. Senegal
  27. Sierra Leone
  28. Somalia
  29. Sudan
  30. South Sudan
  31. Tanzania
  32. Togo
  33. Chad
  34. Tunisia
  35. Uganda
  36. Central African Republic
  37. Zimbabwe

Asia

  1. Afghanistan
  2. Bhutan
  3. Iraq
  4. Iran
  5. Yemen
  6. Cambodia
  7. Kyrgyzstan
  8. Laos
  9. Mongolia
  10. Myanmar (Burma)
  11. Nepal
  12. North Korea
  13. Philippines
  14. Sri Lanka
  15. Syria
  16. Tajikistan
  17. Turkmenistan
  18. Uzbekistan
  19. Vietnam

Europe

  1. Belarus (White Russia)
  2. Bosnia and Herzegovina
  3. Russia (currently not in Swift)
  4. Ukraine

North and Central America, Caribbean

  1. El Salvador
  2. Haiti
  3. Honduras
  4. Cuba
  5. Nicaragua
  6. United States of America (USA)

South America

  1. Bolivia
  2. Paraguay
  3. Suriname
  4. Venezuela

Oceania

  1. Fiji
  2. Micronesia
  3. Palau
  4. Papua New Guinea
  5. Solomon Islands
  6. Timor-Leste
  7. Tonga
  8. Tuvalu

 

This list is based on the information from the provided document from the official website of the German Federal Central Tax Office and the knowledge about worldwide recognized countries. Please note that some countries may be negotiating or planning to join the CRS in the future. This list may contain errors. Have you discovered an error? Please write to us.

You might also be interested in: Is there still banking secrecy?

 

Possible solutions for wealthy entrepreneurs

An increasingly popular option for wealthy entrepreneurs is to settle in a tax-friendly country that does not tax foreign income. Examples of this are

  • Malta
  • Ireland

There is no problem with the CRS in these countries, as the tax number and address from this country can be provided and legal foreign income does not have to be reported or taxed. Of course, there are also options without emigration, such as the Multi-Member LLC in the USA.

For people who are constantly traveling and do not have a permanent home, or for those who prefer confidential banking and have fundamental concerns about the exchange of information, the option remains to open an account in a country that does not participate in the CRS.

 

Current overview of non-CRS countries and their status in the EU

Countries that do not report account information to the customer's tax domicile.

In this table, we have also taken into account the EU status of the countries, including gray (FATF) and black lists.

Country Description List/Status
United States (USA) USA does not report US LLC accounts established by citizens of other countries. Based on this, you have a 100% offshore company with an anonymous LLC in the USA. How to open an LLC in the USAHow to form an Anonymous LLC Not on the gray or black list.
Armenia Armenia is an emerging financial center without CRS. Opening an account is relatively easy, with excellent banks such as Ameriabank and Evocabank. Western and Eastern currencies can be used and interest rates on local currency are high. EU gray list.
Botswana Botswana is one of the most stable countries in Africa with a well-developed infrastructure and low crime rate. English is the official language. Banks such as Standard Chartered and Absa as well as local banks make it possible to open an account in around a week. Not on the gray or black list.
Dominican Republic The Dominican Republic has a decent banking system, despite being a developing country. There are local banks and savings banks as well as the Canadian Scotia Bank. Not on the gray or black list.
Georgia Georgia offers one of the easiest ways to open a bank account, even without being a resident. TBC Bank and Bank of Georgia are leading banks. Although Georgia will soon join the CRS, it is still a great location for banking. Not on the gray or black list.
Guatemala Guatemala is attractive for expats, with banks such as Agromercantil and Azteca Bank, as well as Citibank. However, it is not recommended to store all your money in Guatemala. Not on the gray or black list.
Cambodia Cambodia is one of the last truly favorable countries with a stable economy since the 1990s. Strong local and international banks are present and high interest rates are offered on US dollars. A business visa may be required to open an account. Not on the gray or black list.
North Macedonia North Macedonia has low flat tax rates and incentives for businesses. The banking system continues to develop, with local banks owned by European banks such as Société Générale and ProCredit Bank. Not on the gray or black list.
Philippines The Philippines is an easy place for expats to open a bank account. Large international and strong local banks are represented and interest rates are reasonable. The Philippines is highly FATCA compliant and banks such as HSBC and Metrobank are very attractive to expats. FATF gray list.

De facto non-CRS countries

Some countries don't really want to be part of the CRS, but sign up because they want to be removed from a gray list. Some are skeptical that all participating countries are actually able to share information. Some countries claim that although they have signed up, there is no real mechanism for participation on the ground. It is likely that this will change over time, but it is reasonable to assume that Belgium, for example, enforces the rules more strictly than Vanuatu. A good example is Liechtenstein and Switzerland. Liechtenstein has always boasted of being the leader in the CRS, but still does not exchange data with Switzerland, which infuriates the Swiss, as Liechtenstein is known to be the country where the Swiss evade taxes. This shows that many countries are very selective about who they exchange data with when they can afford to.

 

The best-known offshore countries that have long since joined the CRS

When you think of Offshore destinations the following countries and regions often come to mind:

  1. Switzerland
  2. Luxembourg
  3. Singapore
  4. Bahamas
  5. Cayman Islands
  6. Bermuda
  7. British Virgin Islands (BVI)
  8. Panama
  9. Isle of Man
  10. Malta

For a long time, these were considered the most famous "tax havens" and offshore paradises in the world.

However, the myth of these countries as places with impenetrable banking secrecy and complete lack of transparency has changed in recent years. The reason for this is the agreement on the automatic exchange of information (AEOI), also known as the CRS.

Of the ten offshore destinations mentioned above, all have signed the AEOI.

Country Year of joining Main effects
Switzerland 2018 Limited application, most accounts affected
Luxembourg 2017 Full disclosure of information, possible higher tax obligations
Singapore 2018 Disclosure of information with some exceptions
Bahamas 2018 Disclosure of information, exceptions for accounts prior to 2017
Cayman Islands 2017 Disclosure of information with some exceptions
Bermuda 2017 Disclosure of information with some exceptions
British Virgin Islands (BVI) 2017 Disclosure of information with some exceptions
Panama 2018 Disclosure of information with some exceptions
Isle Of Man 2016 Complete information transfer
Malta 2016 Complete information transfer

 

CRS status of former offshore countries in 2024

Country CRS status Reporting obligation for German financial institutions from Special features
Switzerland Standard partner 2017 Important financial center in Europe
Luxembourg Standard partner 2016 Major European financial center
Singapore Standard partner 2017 Important Asian financial center
Bahamas* One-sided exchange No obligation to report Germany receives data, but does not send any
Cayman Islands* One-sided exchange No obligation to report Germany receives data, but does not send any
Bermuda* One-sided exchange No obligation to report Germany receives data, but does not send any
British Virgin Islands* One-sided exchange No obligation to report Germany receives data, but does not send any
Panama** New complete replacement 2018 Exchange ratio recently changed
Isle of Man Standard partner 2016 British Crown Estate
Malta Standard partner 2016 EU member state

Notes:

  • (*) indicates countries with one-way exchange: Germany receives information but does not transmit any.
  • (**) indicates countries for which the exchange ratio has recently changed.
  • German financial institutions must nevertheless collect relevant financial account data for all countries, including those without a reporting obligation.

Analysis:

  1. Traditional financial centersSwitzerland, Luxembourg and Singapore are fully integrated into the CRS as important international financial centers.
  2. Offshore financial centersBahamas, Cayman Islands, Bermuda and British Virgin Islands have a special status with unilateral exchange of information.
  3. Special developmentsPanama has recently changed its exchange relationship and is now a fully-fledged CRS partner.
  4. European integrationEU members such as Malta and European territories such as the Isle of Man joined the CRS early on.

 

The trend

This overview shows that traditional "tax havens" are also increasingly being integrated into the international exchange of information, albeit with some restrictions. The development in Panama illustrates the trend towards greater transparency.

By participating in the CRS, these countries are obliged to automatically transfer information on bank accounts and assets of foreign citizens to their respective home countries. This means a significant loss of confidentiality and privacy for offshore structures in these jurisdictions.

The once strict protection of banking secrecy and the possibilities for complete Anonymity for offshore companies and accounts have thus been severely restricted. While these countries continue to offer attractive locations for legal tax optimization and asset protection strategies, they must now adhere to significantly higher transparency and compliance standards.

 

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What is reported in the automatic exchange of information?

List of reportable account data within the framework of the automatic exchange of bank data (CRS)

  • Name, address, country of residence and tax identification number of the account holder
  • Date and place of birth
  • Account number and name of the bank or financial institution
  • Account balance and total credits in the current calendar year
  • Investment income (e.g. interest, dividends) and income from certain insurance contracts
  • Proceeds from the sale of financial assets

Are accounts with a balance of zero also reported?

As part of the Common Reporting Standard (CRS) information is also generally provided on Accounts with a balance of zero exchanged. However, there are a few special features:

Obligation to report zero accounts

Accounts with a balance of 0 must always be reported, unless they have been closed. This ensures seamless monitoring and prevents potential tax evasion.

Exceptions for certain account types

There are exceptions for certain account types. For example inactive accounts or Accounts with very low balances be exempt from the reporting obligation under certain circumstances.

Relevance of account movements

Even if an account has a Zero balance the Account movements be relevant during the reporting period. In particular, the Total credits reported in the current calendar year.

Purpose of the comprehensive reporting

Reporting zero accounts helps to obtain a complete picture of a taxpayer's financial situation and to uncover possible tax avoidance strategies.

 

Conclusion

Finally, it is important to comply with the law. It is not forbidden to open an account in a country where the CRS does not exist, but Money before tax is a problem and is illegal. However, it is understandable to want to hedge against banking risks, systemic risks, currency risks and other dangers in our chaotic world by holding multiple accounts around the world. These are all legitimate reasons, as long as you declare what needs to be declared, such as income and holding foreign accounts.

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FAQ: Countries that do not participate in the automatic exchange of information CRS

1 What does automatic exchange of information (CRS) mean?
CRS stands for Common Reporting Standard, an initiative to combat tax evasion in which countries automatically exchange financial data.

2. which countries do not participate in the CRS?
At present, the USA, Armenia, Botswana, the Dominican Republic, Cambodia, North Macedonia and the Philippines are certainly among the most promising countries. non CRS countries.

Remark: The USA currently has no plans to join the CRS system in the near future. One of the main reasons for this are concerns regarding the VAT of US companies. If the USA joins the CRS system, many US companies could be forced to pay VAT retroactively.

3. why do some countries not offer CRS participation?
Reasons vary from data protection concerns to political or economic considerations.

4. are there advantages if countries do not participate in the CRS?
Yes, it could offer tax relief and increased financial privacy.

5. can tax information be kept secret in countries without CRS?
Yes, in countries without CRS there is no obligation to automatically share tax information with other countries.

6 What role does the USA play in the CRS system?
The US is not part of the CRS, but uses its own system, FATCA, to collect international tax data.

7. how does CRS participation influence the opening of a bank account?
In CRS countries, financial information is shared automatically, which is not the case in countries without CRS.

8. are offshore accounts in non-CRS countries legal?
Yes, as long as the laws of the country are complied with, offshore accounts are legal.

9. is anonymity better protected in CRS-free countries?
Yes, because these countries do not share financial data with other countries.

10. is Russia in CRS ?
Russia is still formally a CRS participant, but the actual exchange of information with many countries has been suspended due to the current geopolitical situation.

 


Sources:

Participating countries 2024 final list

Official website of the Federal Central Tax Office

PDF, 617KB, File is not barrier-free

Final list of participating countries
Status: June 13 2024

Legal information

It is important to emphasize that this article is intended to help people be fully compliant with the law and still achieve greater privacy. It is strongly recommended to follow all applicable laws. It is not prohibited to open an account in a non-CRS country. In Germany, there is no foreign account reporting requirement, but residents of other countries, such as the US, are required to report foreign bank accounts, even if the information is not automatically exchanged. Some governments prohibit their citizens from banking in other countries, so it is important to check the rules of the country of residence and abide by the laws.

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Disclaimer: Please note that the above dates, tax rates and regulations may change over time. Do not make any independent decisions without first consulting an expert for your individual situation. It is in your interest to always receive individual information from an experienced expert who knows your situation. This information is for informational purposes only and does not promote illegal activities, including tax evasion.

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