CRS: What if no Tax-ID is given? Can they still collect your data?

[Brobbel]

I have a bank account, and have not given my TAX-ID.
Would it in general‌ mean, that if a bank or whatever does not have your Tax-ID, they can not‍ send anything regarding CRS to your tax country?

My for example is Germany.
I mean⁠ how will they identificate you or search you in their systems, it can not be⁤ through name, as many people could have the same name.
Also the ID or Passport⁣ number is something which changes every 10 years at least.

The system of CRS must⁢ identificate and collect data based on the TAX-ID. Without that, you can not exists there.︀

What you think?

 

[Sols]

They can still report it to Germany and leave it to the authorities to figure‌ out whose account it is based on name, date of birth, address, and historical and‍ current ID/passport number records.

Most likely, though, the bank will eventually ask you for your⁠ tax ID.

 

[dread pirate]

It's a really good question. If you look up AEIO regs it's supposed to be‌ everything from name, dob, address, balance, deposit and withdrawals, and tax id. Basically, everything that‍ could identify you without question.
I suspect that banks/financial institutions that don't ask for all⁠ this data are not exchanging info rather they are merely being KYC/AML compliant.

 

[RexS9999]

What if one is careless and gives a tax id number off by a few‌ digits. A simple mistakes happen. Anyone know the answer?

 

[Sols]

It depends on the issuing country. Some tax IDs can be validated.

 

[Rzeznik]

In homeland when I go to local bank show ID with‍ local address then is obvious that I am tax resident there.
MY TIN is my⁠ default personal number this number is placed on ID, I in most cases that number⁤ is somewhere on ID or on passport.

There could be situation that in papers/documents when⁣ you were signing agreement with bank account you declared tax residency in place of ID⁢ address.

For CRS reporting you should declare TIN, service should ask you for TIN.
To filter fake reports they usually collect utility bills / bank statements with address.
Some bank︀ like swiss one want from you tax residency certificate.
Banks institution often asked me about︁ my TIN. (Wise for bank account wanted)

Anyway now I was asked by Bitstamp for:︂
- Tax residency
- Citizenship
- Place and country of birth

So I see that︃ in future you tax information will go to all those places.
Most possible scenario is︄ for me :
1) CRS sends to declared TAX residency country NOW depends that you︅ are paying taxes or not information stays in X country
2) Citizenship if you were︆ not registered taxpayer ( or not payed any taxes ! ) your data goes to︇ country of your citizenship and country where I have been born
(to combat buying citizenship︈ )

The worst scenario is that all your tax data goes to all those places︉ but probably should not happened.

In AMLVI there was something about central base of all︊ taxpayers for CRS/Crypto to compare and seek anomalies.
Institutions have to maybe collect that data︋ now but they will send it later once particular countries will implement law in their︌ system.
(that is my assumption)

 

[backpacker]

This is -for the most part-‍ a result of Bitstamp realizing that it would be better to have at least basic⁠ KYC.
Highly unlikely.
Even with a bank who takes KYC seriously they⁣ will report to local authorities ONE tax residency. There are very rare cases when they⁢ will report more than one, but that is what you can control: Bring proper documentation︀ and contact details right from the start and you will be reported to that place.︁

Note: The FI prepares CRS data for local authorities according to local regulations, set up︂ in accordance with the CRS framework. Local CRS execution regulations differ from country to country︃ slightly. Local authorities then forward this information on a fixed date yearly to foreign authorities.︄
Since when is that?︆
Example: A retired Japanese citizen with bank account in Korea who lives permanently in Bahrain︇ -> His bank account will be reported to Bahrain. Even if he pays no local︈ taxes, Bahraini authorities have no reason to forward his data to Japan (CRS does not︉ provide the possibility of triangle information).

Under CRS your data goes to the country where︊ you have your tax residency. That's it. CRS does not provide for anything else.
Of course, within the EU your data will be exchanged between various tax authorities. However, this︋ mechanism has nothing to do with CRS.

 

[Rzeznik]

There was‍ full KYC before there mandatory for all.
Direct impulse to update data was entering AML6⁠ in June 2021. So companies/institutions within EU have to compile with it.

Depends on situation if nothing suspicious happen then is like you⁤ are saying.
But once system detects unusual transaction that have to be reported to local⁣ FIAU (they investigate and share report to others FIAUs may be involved in EU.
Suspicious transactions will go to all places when is suspicious.
https://ec.europa.eu/info/sites/default/files/diagram_aml_2018.07_ok.pdf

Yes true.

You have right whole reporting will be not under CRS︆ but new ongoing system in EU.
But sharing of financial data will be in EU.︇
I was simply thinking in shorthand. There will be a system that grows and grows︈ until every euro cent is analysed in this database. Surveillance never goes backwards.

https://www.eba.europa.eu/eba-consults-its-proposals-central-amlcft-database

 

[backpacker]

@Rzeznik
Thank you for the clarifications.︂ I now get your point: It is "forward-thining". You explained what may happen in the︃ future (and what is many parts already reality in the EU).
I agree that in︄ the future there will definitely be changes to CRS. If I am not mistaken the︅ OECD announced already sort of a review but I am not exactly an expert in︆ this.

 

[sublety22]

I Live in EU. Does anyone know of a crypto friendly bank that does not‌ share tax information with other countries ?