Where Switzerland Misinterpreted the CRS Implementation Handbook

Offshore Tax with HTJ.tax · Feb 15, 2026 · 4m

This episode examines a narrow but consequential interpretative issue: Did Switzerland extend the CRS look-through rules for FI-trusts beyond what the OECD Implementation Handbook actually provides?The debate centers on Chapter 6.3 of the CRS Implementation Handbook, specifically paragraphs 254–256 (pp. 109–110), dealing with trusts that qualify as Reporting Financial Institutions.🔎 The Text of the HandbookParagraph 254 – Identifying Reportable AccountsThe Handbook states:The debt and equity interests of a trust constitute Reportable Accounts where they are held by a Reportable Person.It then…