CRS reporting of vIBAN?

[polka]

I'm trying to figure out what gets reported from the accounts that I have and use in the context of my current tax residency (EU) and future tax residency (other EU).

For example, if I have an account at one of the crypto exchanges and they issue me a named EUR vIBAN for deposits, and it happens that the outgoing payments also come from the vIBAN. My understanding is that I am not actually the account holder, but the exchange is (the reason they only allow you to move funds to/from your own bank account). Questions:

1. Does this vIBAN get reported to tax authorities? If I hold EUR in the exchange, is that money in my vIBAN and reportable?
2. Do crypto exchanges even report under CRS or other similar framework?
3. If I move to another country later this year and obtain residency, would they report to that country as well, or only where I have tax residency?
4. If I change tax residency next year, but move this year and change residency, would they report the information to the new tax resiedency authorities only for the 2025 year end, or would they send them the 2024 year end to both the previous, and the current authorities?

Hopefully someone with more experience can shed some light, as I am looking to remain compliant and anticipate any tax implications of the vIBANS. Thanks

 

[Sols]

A crypto exchange that issues vIBANs is also an EMI, PI, or bank (or partnered with one), which means CRS applies just the same to any other EMI/PI/bank.

For reporting purposes, virtual accounts are the same non-virtual accounts. It would be wise to assume that vIBANs are reported same as regular accounts. Anything else would just be a regulatory oversight by the responsible party.

Not if they are a pure crypto exchange. However, if they are, then someone else is providing the vIBAN and that party is responsible for reporting.

You might get reported to both countries, if there is doubt about where you actually live. However, in most cases, if you're just some random nobody, they'll report simply based on what you self-certify is your place of residence.

Same as #3.

 

[polka]

So then if OKX issues a vIBAN from OpenPayd in Malta, then OpenPayd would report the account for CRS purposes to my fiscal residency authorities with that IBAN and balance.
That begs the question if the EUR in OKX is held under that vIBAN and will appear as a balance or if the account is just used for deposits and withdrawals. Better not to trade vs fiat anyway unless actually off-ramping.

For example, I know a relative who uses Crypto.com and was issued an vIBAN from same MT OpenPayd, but if they top-up their card with crypto, there is a separate card account, not the vIBAN account that gets topped up.

I can only assume card accounts get reported as well.