How Switzerland Misapplied CRS Look-Through Rules for Trusts

Offshore Tax with HTJ.tax · Feb 13, 2026 · 6m

In this episode, we examine a controversial development in Swiss CRS practice: the extension of look-through obligations for trusts that qualify as Reporting Financial Institutions (FI-trusts).The issue centers on whether a trust must look through entity account holders—even when those entities themselves qualify as Financial Institutions.🔎 The Legal BackgroundUnder the Common Reporting Standard (CRS) issued by the Organisation for Economic Co-operation and Development, an account holder that qualifies as a Financial Institution (FI) is generally a non-reportable person.For FI-trusts, equity…