16/06/2026
Many people still set up international structures expecting a degree of privacy. Under the Common Reporting Standard, the relevant tax authorities already receive the information automatically each year.
CRS was developed by the OECD and adopted by more than 100 jurisdictions including Malta, which implemented it through the EU's DAC2 directive. A Maltese account held by a non-resident is reported to their country of residence, and an account held abroad by a Malta resident is reported back to Malta. It covers balances, interest, dividends and proceeds, and reaches into certain trusts and foundations.
The point is straightforward: transparency is the baseline. A structure built on genuine residence and real substance has nothing to fear from automatic exchange. We help clients reach that position: drwerner.com/en/services/hnwi-services