CRS Commentary on Financial Institutions Holding Equity Interests

Offshore Tax with HTJ.tax · Feb 17, 2026 · 3m

This episode examines a pivotal provision in the CRS Commentary—paragraph 178 (Section VIII, C(4))—and its implications for trusts that qualify as Reporting Financial Institutions (FI-trusts).The key issue: When equity interests in an FI are held through a Custodial Institution, who reports?📘 The CRS Commentary (p. 178, C(4) – Equity Interest)Under the Commentary issued by the Organisation for Economic Co-operation and Development, paragraph 69 clarifies that:In the case of a trust that is a Financial Institution, an “Equity Interest” is considered to be held by any person treated as a…