Singapore Government Sets Small Business Controllers Astir As AEOI Comes Knocking

singapore registered controllers red tape
Image by James Petts
Until now the controllers of most local businesses could sit quietly in the background, passively earning money. To the world at large they appeare to be unconnected with the company providing their income or wealth. In the new world of AEOI and FATCA, goverments no longer condone such anonymity. These folks are now deemed Registerable Controllers” whom we describe in more detail further on.

For government departments to learn who actually controls the business is a significant chore today. So legislation will now go into effect on 31 March 2017 to rectify that problem.

From that time forward, some companies must maintain a register of their “Registerable Controllers”. Government owned companies, financial institutions and companies traded on a stock exchange are exempt.
Their registrar’s office or the registered address will keep a new document known as the “Register of Controllers”. You can find more detail on it here

Registerable Controllers

The legislation is interesting in that it doesn’t say who IS a registerable controller; it defines who isn’t one.
If you (either as a person or a company) control a company indirectly through one or more controllers, you aren’t a controller. In that case, don’t have to appear on the register. In other words, for example:

  1. If you are company A and own or have a significant interest in company B and
  2. company B owns company C,
  3. then B would have to register with C as its controller and
  4. A would have to register with B as its controller.

Because 25% interest in the company or in its voting shares is the cut-off. A company could have up to four registered controllers, if they each controlled 25% of the voting shares.

More Information

This is just a brief summary of how the law works. There are more details for the immense variety of ownership and control structures that could exist, but the principal is always the same:

  1. If the company is already statutorily required to keep a record of its controllers somewhere, it isn’t required to maintain a second copy.
  2. If an individual or legal person controls a company indirectly through one or more companies, they need only be listed at the directly owned company(ies) subject to a above.

As always, the devil is in the details, which you can find here.

FATCA, AEOI and Economic Reformation

Economic reformation to retreat from planetary boundaries
Bumping Against Planetary Boundaries. Derived from globe.svg by Ninjatacoshell

AEOI and FATCA are symptoms of the failed version of capitalism that underlies global political turmoil and the crisis stage our planetary home has already met. Politicians worldwide are desperate to provide enough for their voters to keep themselves in office, but they are failing. Their failure causes disappointment, anger, war, devastation and flight. Populists with worse ideas are attempting to cash in on the chaos. They will be even less successful.

The Failure of Conventional Capitalism

We think we know that capitalism is all about growth. If we could make enough stuff, everyone would be better off. Shallow thinking. Although we all know that the Earth is finite and that we’re not leaving, we act as though Earth’s resources are infinite. The capitalism that we embrace as our secular religion takes that as a given. But the collapse of Venezuela, Somalia, Syria, Western Sahara, the encroaching of sands onto Chinese agricultural lands and the disappearing summer sea ice of the Arctic tell another story.

AEOI and FATCA Measure Desperation

If things were proceeding normally, the OECD governments would not be desperate for revenue. After all, they suck in monumental amounts of revenue every year, that should be enough. Sad to say they then disgorge it wastefully. To top that off, they pilfer it from the pockets of those who need it most and pass it to those who need it least. So they get remarkably little bang for the buck and so do we. This topsy-turvy allocation may align with a fairy-tale version of capitalism but it dispenses with capitalism’s promise.

That’s not news to you, I’m sure. If governments spend revenue unwisely, their first response is to seek more revenue, not to spend wisely. Having emptied the pocketbooks of 95% of their citizens and not wanting to bother the rest, they look farther afield. AEOI and FATCA are the tools they use to suss out additional revenue sources. You look like a likely candidate.

Unforced Change Not in the Cards

Liberals, Socialists, Conservatives and NeoLiberals all suffer from the same illusion that the problem of current debt is solved through future growth. They have to believe it. If they don’t, their whole system collapses. The trouble is that even children can now see that the emperor has no clothes. Politicians cannot see the fallacy because they must not see the it. If they do, they will have no choice but to do what’s necessary to make things better. What could be more unwise than that?

Wealth Concentrates as the World Deteriorates

The structure of today’s capitalism all but guarantees that not only rent-seeking (seeking unearned income) is rife but also ensures through self-reinforcing rental mechanisms greater and greater wealth will accumulate faster and faster. It is accumulating so fast now that this may be the year that one person owns as much wealth as 99% of humanity. At the same time, human population continues to climb and global warming continues to increase with no halt in sight.

Unstopped, global warming will kill us all. Unstopped, population growth will kill us all. And unstopped, wealth concentration will kill us all.
One thing we know with absolute certainty, in a finite system, exponential growth will not continue indefinitely. That’s where we are today. Believe what you want, reality doesn’t care.

Measuring Inequality

I need to make a slight aside here so that you can understand where you are in the grand scale of things. If you have more than US$10,000 in wealth then you have more than 71% of the people on Earth. If you have US$100,000, you have more than 92% of the people on Earth and if you have US$1,000,000 you have more than 99.4% of the people on Earth. And if you are the richest person, you have as much as everyone else put together. Ahhhh the schadenfreude and envy that you must feeling and feeling guilty about, right now, for you are so far above the bottom but the top is out of reach.

There is no way to graph your wealth in relationship to Bill Gates or Warren Buffet. If you have only a few million in wealth, your dot on the computer screen will vanish into nothingness. You’ll cease to exist. Every time he swings his golf club a multi-billionaire accumulates more wealth by the mere fact of his existence than you will in a lifetime of work. Perhaps you think that’s okay. I don’t.

Traditional Capitalism Encourages Shoddyness

Somewhere along the way progressing out of my lower middle-class life I learned that a little extra money spent on clothing bought clothing that was an order of magnitude better in terms of durability and wearability. One could easily spend twice as much on a piece of clothing and get ten times the wear out of it. As it turned out that was true of many things. (Not cars, unfortunately. or smartphones.) Those who patronise Walmart ensure that they’ll need to keep patronising Walmart because the quality is so poor that they have to keep shopping there for replacements. Savings in the world of shoddy are hard to come by.  A few more dollars spent at Land’s End, Duluth or L.L. Bean can mean a decade’s difference in the life of a skirt or shirt. Longer-lived clothes are one more way to add to your bank account.

This isn’t meant as an anti-Walmart tirade, it is to point out that mere numbers do not tell the story of economic progress. Take Las Vegas as an example.

Las Vegas – Home of the Ephemeral

Las Vegas Boulevard is a strip of disposable multi-billion dollar dream castles and fantasies.  The Neon Museum in Las Vegas is the final resting place for the signs of once world-famous casinos that are no more. It houses the last echo of casinos that were wondrous, shoddy creations in their day; creations that deteriorated and outlived their use-by dates and were imploded to make way for equally shoddy successors.

How much more money would have had to have been built into the design and construction of each of these buildings to extend their lives for one or two hundred years?  Ten to fifteen percent. That’s all. But of course the pay back would have started a little later and taken a little longer, and that was all that mattered. It should be obvious that this sort of thinking is a direct contradiction to universal principles and patterns of systemic health and development.

What Can be Done

Regenerative Capitalism offers a way out. But it calls for a radical shift in perspective. Growth is out. Improvement is in.

Here I adapt page 8 and 9 of Regenerative Capitalism

These are the eight characteristics of a healthy human system:

  1. A Healthy System is Innovative, Adaptive, Responsive.  The most innovative, adaptive and responsive systems are the ones most likely to prosper in a world of change.  In Darwinian terms, they are the most “fit”.
  2. It Empowers Participation.  In an interdependent system, fitness comes all parts contributing and taking from the system so that the whole benefits as well as the parts.
  3. A Healthy Human System Honors Community and Place.  Each human occupies a unique place in the system and came to that place through a unique history. A healthy system will honour each person’s place and history.
  4. It Fosters Edge Effect Abundance.  We are a collection of small systems and maximum creativity occurs where different systems touch, not at the center where things are uniform. Working collaboratively across the edges enhances each system.
  5. It has Robust Circulatory Flow.  Economic health is dependent on the robust circulation of money, information and resources.  Sequestering these in the hands of a few leads to economic death.
  6. A Healthy System Seeks Balance.  The Regenerative Economy seeks to balance efficiency and resilience; collaboration and competition; diversity and coherence; and small, medium, and large organizations and needs.
  7. It is In a Proper Relationship.  Humanity is an integral part of an interconnected web of life in which there is no real separation between “us” and “it.” The scale of the human economy matters in relation to the biosphere in which it is embedded.
  8. It Views Wealth Holistically.  True wealth is not merely money in the bank. It must be defined and managed in terms of the well-being of the whole, achieved through the harmonization of multiple kinds of wealth or capital. These  include social, cultural, living, and experiential capital. The human system must also be defined by a broadly shared prosperity across all of these varied forms of capital.

Where to Start?

AEOI and FATCA are, as I mentioned, tools that demonstrate the desperation of governments to increase their revenue streams. Resistance is futile. They will have their way sooner or later and you must become comfortable with that fact. There are two things you can do, and both are important:
First, you can avail of legal options that will reduce or eliminate the taxes that you now pay through careful tax planning. I personally detest the idea that we have a system that enables this form of legal cheating, but that’s the system we live in.Contact us for some ideas.
Second, Read Regenerative Capitalism.
Third, Get locally involved, no matter where you are. If you are reading this, you are the kind of person that can make things happen in your community or communities adhering to the principles above. Do it.

AEOI, Taxes and Growing Your Market in a Static World

Birth Rate Map Presages AEOI policy.

Map by Ali Zitan Released into the public domain under Creative Commons CC0 1.0 Universal Public Domain Dedication

You can get a quick intimation of what your market is going to look like in the future with a simple look at the map above. You can also determine what each market’s tax policies, including AEOI and BEPS, are going to be by looking at the same map.

Demographics→Taxes→AEOI

If your market is not experiencing a growth in population then you will find business gets harder over time. For two hundred years, demographics have worked in favour of the business person. Growing populations meant more business. Now, the Middle East and Africa account for almost all of the world’s population growth. Business can no longer depend on mere population growth to carry it forward. As the next graph indicates, world population is reaching a point where it should become static in the future after which it will slowly decline.
Declining fertility rates force AEOI policies

If you are in a country such as Singapore or Dubai you must be thinking “does this guy have any idea of what he’s saying?” Well, yes, I do. Don’t be deceived by your local situation. There are a few places where populations have been growing substantially and quickly. Not only small, hot-house economies like Singapore and Dubai have experienced rapid growth in a short period of time. Many cities around the world are growing much more rapidly than their countries. The U.S. and Canada continue to grow their populations as a result of their liberal immigration policies. Each of these trends marks something different in terms of long-term sustainability.

The Rise and Fall of Cities

Cities such as the coastal cities and provincial capitals of China have experienced phenomenal growth.  That was to be expected as workers from the hinterlands flocked to the cities to provide the cheap labor for new factories. Dubai and Singapore have had high population growth as a result of temporary labor that has come to fill vacant jobs. But the jobs are artificial and result from temporary laws and regulations.

Population growth, in other words, has not been organic. It has been brought about by external forces that have been of immediate benefit but there’s no internal foundation for them. Such economies are far more fragile than they may seem. As they seek an even playing field, protectionist pressures of Europe and North America will make jobs disappear almost as quickly as they came. The cities of tomorrow that dot the Asian landscape would quickly hollow out.

China. It’s Always China

China’s situation is a case in point. Anyone whose business is in any way related to China is sitting on a time bomb.
China is so successful with its exports for three unsustainable reasons:

  • First, it subsidises its manufacturers by providing virtually no enforcement of either environmental policy or labor rights.
  • Second, it pegs the Yuan to a price significantly (up to 20%) lower than the price the market would naturally support, and
  • finally, it directly subsidises its manufacturers, making it possible for them to manufacture at or below cost and still make a profit.

China’s unbalanced approach to trade drives populist movements in Europe and America. You can bet that Donald Trump will act to create a balanced trade system starting on 20 January, 2017. The consequences for much of Asia are going to be dire over the short and medium term. Given China’s positive economic presence in every Asian economy, every country will be affected.

Demographics are not the Whole Story

There are three trends that will modify the consequences of the decline of population growth:

  • The Rise of the Robots
  • Distribution of the fruits of success
  • Economic rise of the many

Each of these is worthy of a separate discussion. For the moment I’d like to discuss the interplay of the final two.

Wealth Inequality Drives Economic Collapse

Under our current distribution systems, there is a link between the work you do and your ability to consume. Your work may entirely beneficial, as with a health worker. Or your work may be pernicious, as with a cocaine dealer. Both have in common is that they must work to generate income and survive.

Unskilled or semi-skilled labourer, too, needs to work to generate an income under today’s system and this is especially true in Asia. As jobs disappear, so does income. No income means no consumption. Under today’s policies, that means that your business is likely falter or die as net jobs move out of Asia.

Those at the top of the income distribution won’t be bothered; quality time is their issue, not food and shelter. If your business depends on the bottom 99% of society, you are probably in for a rough ride.

Government Response

Governments really have no choice but to locate revenue sources that are eluding them or to raise taxes. Or both. Between twenty and forty trillion dollars in wealth are being hidden from governments today. As much as half of it provides no economic benefit… it is simply hidden away and gathering dust. Even the money that is supposedly in the economy shows up as overpriced stocks and overpriced real estate. That doesn’t create jobs. All those overpriced assets are simply waiting for the next, greater fool to purchase them. When the implosion comes, there won’t be any greater fools. The Ponzi game will be over.

Governments know this. They want those assets in circulation. They want to create jobs. And so they must scare the money back into productive use in the economy or take the money and do the job themselves. It really isn’t very complicated. Given that, AEOI, the Automatic Exchange of (tax) Information is nearly ideal.

Can Anyone Resist AEOI?

AEOI will be nearly universal. Only countries with adequate demographics, economic and political/military power can resist. Take another look at the map. Each purple country has demographics working against it. As you can imagine, each has an urgent need for AEOI to expand its revenue. If we check here we can find out which ones have low unemployment. Because we are looking for strong economies, we look for low unemployment. It seems just a bit of a surprise that not only the U.S. shows up favourably, so does Mexico. And Chile is another good performer. Finally we want to add in the test of political/military power. Among the three finalists, the dominance of the U.S. is unquestionable. Consequently, we rate the U.S. as the least susceptible to AEOI.

You probably aren’t very happy with that conclusion. The mass media, popular wisdom and your personal feelings may put you in denial. While you may wish it were some other country, the country most likely to be able to resist AEOI is the United States.

We have arrived at this conclusion through various chains of reasoning. It seems like no matter where we start, we end up at the same point: the U.S. is the county most able to resist AEOI.

With the offshore jurisdictions ability to hide your assets and the BEPS program killing transfer pricing schemes, the U.S. is shaping up as the place where you will be able to avoid AEOI, but may also be able to more favourable tax treatment than you can at home. Sometimes truth is stranger than fiction. If you want to dig into this more deeply contact us here or read some of our earlier postings on AEOI, CRS and BEPS in this blog.
F. G. Bouman

AEOI vs FATCA Don’t Let Preconceptions Mislead You

OECT Logo

By Nzeemin [CC BY-SA 3.0 (http://creativecommons.org/licenses/by-sa/3.0)], via Wikimedia Commons

AEOI, FATCA, CRS and BEPS,not to mention the OECD and the IMF are impacting you in ways they never have before. It is a fair bet that the almost daily changes that are occurring in the banking world today have most people who read this column behind the curve. When that happens to us we tend to fall back on old patterns of thinking. That’s not because of some innate character flaw but because that’s one of the ways the body conserves energy.
Thinking is hard work and your brain is predisposed to be lazy. This is one of those times that you need to give it a swift kick in the behind, so to speak. Old patterns of thinking can end up being very costly to you.
“My life is just fine,” your brain thinks, “I don’t need to be thinking about my bank accounts. It’s just too bothersome and things are going okay.”
A cow’s brain is thinking the same way the day before it heads to the slaughter-house. Life is pleasant until it suddenly isn’t.

Behind the Scenes of AEOI

Virtually every country is in some degree of financial trouble. Misspending, greying populations and crafty citizens are just three of the many causes. When politicians have a problem, their first reaction is to reach for the chequebook but often these days the bank account is overdrawn. Because they want to be re-elected, politicians will do almost anything before they raise taxes. So they cast around for ways to get money without raising tax rates.
A few years ago the search for taxes led the U.S. to implement FATCA to make it hard for its citizens to hide untaxed money abroad. OECD politicians said “Hey! What a great idea!” and so they came up with a similar plan for their own citizens called the Automatic Exchange of Information (AEOI).

FATCA is born

When the U.S. was trying to implement its early form of international tax reporting the project was an utter failure. Governments refused to co-operate as they all saw an advantage for their banks if they just stuck with the old ways. So the U.S. strong-armed individual banks. “Co-operate with us,” they said, “or you’ll never be able to transfer money or deal in dollars again!”
Unsurprisingly, the banks all stood up, saluted and cheerily waved their little American Flags. It didn’t really matter, they thought, it was only the American taxpayers who were in trouble. Sell them out and everything else will be just fine.

AEOI arrives

That fine state lasted only a couple of years when all the other industrialised countries realised that they could do it too. So they came up with AEOI which, because of the number of nations backing it, is a really big deal. Nearly every country that matters is moving quickly down the road to implementation. By the end of 2019, the world is going to be a very inhospitable place for those who want to minimise their taxes or keep their wealth out of the hands of distant relatives, Even those who simply want to do business efficiently and economically now find their jobs more difficult.

Surprise Winners

Not every country is one where you want to put your money… exchange rates are volatile, governments are fickle and bank staff are unhelpful. And as for the safety of the banks themselves, well that’s a whole story unto itself. There are plenty of offshore banks that take your money and charge you for the privilege. Then they take most of it and invest it, keeping the profits for themselves.
There is no bank authority worth the name to tell you how safe those banks are. Their countries have joined AEOI so they will report your balances and deposits to whatever country you are a tax resident of.
Surprisingly, though, the country that kicked this off, the United States, may now be the best place to put your money. It already has FATCA in place and has no need to participate in AEOI to collect its taxes. It has states that provide a fair level of privacy and its banking regulation is among the world’s best.
For the moment Singapore has advantages like the U.S. Its banks are among the worlds strongest and the MAS is one of the world’s most stringent regulators. For the present, Singapore is slow-walking its participation in AEOI and may ultimately have little more than token participation.
We have taken the time to do a financial and jurisdictional analysis of a number of banks around the world. Contact us for our recommendations and assistance.

SME Must Learn to Navigate the Shoals Between World Orders

APEC members

The Death of the Old Order

China opened to the world in 1978 and by 1991 entered a period of sustained, astounding GDP growth. This growth soon transformed not only China, but the world.
Then, in 1991 the Soviet Union collapsed and its satellites greeted the lifting of the heavy yoke of Communist dictatorship with joy and trepidation.
And finally two years later the nascent EU formed with a number of related organisations quickly falling into place.
Soon, the elements of a new world order had emerged and an era of peace and prosperity was at hand. Or so we thought.
Al Qaeda, the Asian Financial Crisis, the dot com bubble, 9/11, Afghanistan, Iraq, the Global Financial Collapse and the rise of ISIS followed in quick order.

The World Today

Twenty-six years after the collapse of the Soviet Union the world is in disarray. Nations once had a fairly easy choice to make. They could side with the Communist bloc represented by the Soviet Union or with the Liberal Democratic bloc represented by the United States. That clarity is gone.
An undercurrent of anger, frustration and disappointment runs through the former Soviet bloc. Stagnant incomes are the lot of middle and lower classes in the northern liberal democracies. The South of the EU is on the brink of economic collapse and destabilisation.
In China and Russia the disparities between the rich and everyone else are massive. Discontent roils the liberal democracies while it is forcibly put down in China and Russia. None of this bodes well for the near future. Right now, the only certainty for the international SME is uncertainty.

The Near Future is Problematic

While the long-term prognosis is good, for SMEs, the short-term can put them in dire straits. For individuals, the short-term can be catastrophic. Troubles will hinder the road to a bright future.
Here are a few phenomena that will precipitate problems:

  • Income inequality fosters unrest in China and the United States. That unrest will spread.
  • There are too few jobs to go around. Countries will try protectionism. That will hamper export-dependent economies.
  • Malinvestment in a number of countries will trigger Global Financial Collapse II.
  • Governments will increase tax collections because of longer lifespans and slow or negative population growth.
  • Robots and Artificial Intelligence already eliminate some cheap labor routes into the global economy. More will come.

A Hopeful SME Day-After Tomorrow

A mixed world order is rising from the ashes of the old. This is not the unipolar world of American triumphalism. This order will be multilateral and tolerant. Economics will trump ideology.
Options and opportunities are plentiful for the owners of international small or medium-sized businesses. This is unlike their counterparts who are tied to a single city or country.
Take a look at the map at the top of this page. It is notable for a number of things:

  • APEC is where wars are not being fought and terrorism is the lightest
  • More than half the people in the world live in the APEC region
  • Many of the fastest-growing economies in the world are in APEC
  • The world’s two biggest economies are in this region
  • Most of the world’s fossil fuels are in this region
  • Most of the world’s mineral resources are in APEC
  • The world’s strongest military powers are in this region

Here is a map that shows GDP growth rates:
World's fastest growing economies, 2016

Europe and the Middle East Present Problems

APEC should be hopeful while Europe and the Middle East should be less so. Old-world conflicts of a thousand years ago continue to play themselves out. Just as the Romans fought the Germans and the Gauls to enhance their economy, now it is the EU South vs. the EU North. But this time the North is winning. Meanwhile, the age-old conflict between Shii and Sunni Islam is playing out, not only in the Middle East, but on the streets of Europe as ancient hatreds boil over once again.

Short-term Strategy for the SME entrepreneur

Irrespective of where your business is, the next several years will be problematic. Hilda Loe Associates can help you. Protect your assets and diversify your exposure. Uncertainty breeds prosperity for the wise. Contact us.

Switzerland Pursuing Anti-Tax Avoidance AEOI

post-AEOI empty bank vaultThe Automatic Exchange of (Tax) Information (AEOI) protocols are in place. Switzerland is aggressively pursuing agreements with many countries. The list of countries that Switzerland is engaged with includes a who’s who of former tax havens including the newly added islands of Barbados, Bermuda, the British Virgin Islands, Cayman Islands and the Seychelles.

It’s not just Tax Havens

Non-tax havens developing agreements with Switzerland include the entire EU. Outside the EU the following countries are under current discussions with formal agreements slated for signing in 2017: Andorra, Argentina, Brazil, Chile, Faroe Islands, Greenland, India, Israel, Mauritius, Mexico, Monaco, New Zealand, San Marino, South Africa, Turks and Caicos Islands and Uruguay. Switzerland is even further down the road toward implementation of AEOI with Australia, Canada, Gibraltar, Iceland, Japan, Norway, South Korea and the British crown dependencies of Jersey, Guernsey and the Isle of Man.

AEOI Holdouts exist

Expect Switzerland to strike agreements with most of the AEOI signatories in the next few months. However, there are standout exceptions to this: Singapore and the United States. Although they are signatories, these nations are choosing to interpret the agreement in ways particularly favourable to themselves.

U.S. AEOI Slow-walk plus Trump make a Potent Combination

Australian columnist Grace Collier reminds us that Donald Trump’s plans for U.S. taxes and investments will be a powerful magnet. Add in the strong U.S. dollars, internal stability, external strength and a growing economy that is likely to grow faster and the attraction for Australians is powerful. Collier expects to see Australians opening up U.S. companies (probably in Delaware or Nevada) to own their current businesses in Australia and engage in transfer pricing to move the profits into the U.S. for lower taxes and more stability.
Smart investors have been moving their money to the U.S. for some time now. We don’t expect to see this flow slow down any time soon.

CRS/AEOI Strikes: Singapore & Australia Will Exchange Banking Info.

National Australia Bank, Queen St. implements CRS/AEOI

Effective 1 July, 2017 Australians in Singapore and Singaporeans in Australia will find their tax information is now being shared with their home governments [via CRS/AEOI], or rather, the countries in which they are “tax residents”.  Australia has taken what is referred to as the “wide approach” [to CRS/AEOI] which means that up front the financial institutions will be asking their customers to list all of the countries in which they are tax residents and will report this information to the Australian Tax Office (ATO) along with the tax information.  The ATO will make a determination as to whether this information will be shared with any particular country, but it will not be up to the financial institution to make this determination.

Under CRS/AEOI in Australia, there is no minimum account balance required for reporting… i.e. if the account exists, it will be reported. This affects not only Australians and Singaporeans, it also affects Americans with accounts in Australia as, for ease of implementation, the ATO has decided the apply the same rules to FATCA (the one-way reporting of American accounts to the US IRS) as it applies to CRS in terms of financial institution reporting.  Financial institutions aren’t required to apply the CRS guidelines but it is anticipated that they will do so voluntarily in order to ease their own regulatory burden. If misery loves company then Aussies and Singaporeans will probably cheer the joining them in their pain.

To be clear, the ATO has classified the following types of organisations as financial institutions:

  • a Custodial Institution
  • a Depository Institution
  • an Investment Entity
  • a Specified Insurance Company
  • certain Trusts

The ATO has issued these guidelines which, although intended for financial institutions, can be useful for individuals trying to control their tax exposure resulting from CRS/AEOI. If you think that you may have any tax exposure in Australia, you should read through the guidelines; you may find that you are less (or more) exposed than you think.