What is CRS：The core of AEOI compliance
CRS（Common Reporting Standard）It is a standard for the automatic exchange of financial account tax-related information promoted by the OECD (under the AEOI framework)，Requires financial institutions in participating jurisdictions to conduct due diligence on account holders and report to tax authorities，The tax authorities then exchange information with the account holder’s country/region of tax residence.。
For corporate and high net worth clients，The key to CRS is not “whether to declare or not”，But lies in：(1) Is the tax resident status clear?、(2) Whether the entity classification and controller identification are accurate、(3) Whether the self-certification and supporting documents are consistent、(4) Cross-bank、Is the caliber consistent across jurisdictions?。
At the same time, it supports the sorting of individual tax residents.、Enterprise entity classification (active/passive NFE, etc.) and controller penetration capabilities。
Prepare materials based on “acceptable by financial institutions” standards：self-certification、Tax ID number、Proof of address、business substance、Funding sources and transaction rationality explanation。
Unified CRS、Account opening KYC、tax declaration、BEPS/Economic Substance and Corporate Governance Record，Reduce the risk of penetration verification。
Connect accountants/tax accountants and secretarial services in multiple places，Promote data implementation and timetable management。
Which customers need CRS tax consulting more?
CRS compliance issues usually arise when opening an account、Account review、Amplification of cross-border capital flows、Or centralized exposure during tax audit information exchange。It is recommended to carry out special CRS sorting in the following situations:：
- Multi-national living/work/family ties，There is a double tax residency or a change of status；
- The holding structure is complex(BVI/Cayman/Hong Kong/Singapore/Dubai and other multi-layered companies or fund SPVs)；
- High proportion of passive income(Dividend、Interest、rent、capital gains) resulting in the entity being more likely to be deemed a passive NFE and penetrating to the controller；
- Bank proposes CRS supplement(tax number、address、Entity Classification、Controller、Proof of source of funds、Evidence of business substance, etc.)；
- Immigration/status planning in parallel，Required to be a tax resident、The account opening information should be consistent with the asset allocation level (please refer to：Tax residency planning）。
Hong Kong Xintong CRS consulting service scope (enterprise/individual)
We use "verifiable、explainable、"Floorable" as standard，Provide services from diagnosis to rectification、Full link support from files to communication：
1)Tax resident identity and evidence chain
- Sorting out individual/corporate tax residency rules and possible trigger points (number of days of residence、permanent establishment、Actual management place, etc.)。
- Form a factual statement that can be understood by banks and tax authorities、Timeline and evidence list (e.g. entry/exit、live、Hire、family ties、place of operation and management)。
2) CRS entity classification and controller penetration
- Determine whether the account holder is a financial institution、Active NFE or Passive NFE；Identify the scope of controllers and unify their caliber。
- Combined with company articles of association、Equity structure、Board of Directors/Management、Authorization signature and fund flow，Improve the explanation logic of "actual control/ultimate benefit"。
3) Self-certification form and bank due diligence response
- Assist in filling out personal/entity self-certification (Self-Certification)，Verify tax number、Address and declaration consistency。
- Prepare patch package：Company registration documents、business substance、financial summary、Contract and invoice samples、Description of source of funds/source of wealth, etc.。
4) Existing account rectification and compliance management
- Conduct consistency review on historical account opening data，Identify potential misstatements and high-risk accounts。
- Establish internal compliance ledger and annual update mechanism，Support multiple banks、Continuous compliance across multiple jurisdictions。
Applicable if cross-border tax arrangements and agreements are involved，Can be carried out simultaneously：Cross-border tax consulting；Such as information disclosure and economic substance, etc.，Can be referenced：BEPS Compliance Consulting。
Avoid just explaining the clauses，Focus on resolving real inquiries and supplements during account opening/review。
Provide inventory、Reusable evidence packages and explanation templates，Facilitates quick response across banks。
Combining CRS with KYC/AML、corporate governance、Unified management of economic substance and cross-border tax standards。
Delivery process and timetable
collect identities、Residence and tax ID information、Structure and Account List、Main fund flows and income types，Establish risk profiles and priorities。
form preliminary conclusions：tax residence、Entity Classification、Controller identification scope，and possible points of dispute and evidence gaps.。
Prepare/revise self-certification、cover letter、Organization chart、Funding sources and business substance materials；Verification and account opening KYC、Tax filing consistency。
Provide answers and attachments based on the bank's question list；Support multiple rounds of inquiries and updates when necessary。
Establish an annual update and event-triggered update mechanism (identity change、Equity changes、move、changes in business models, etc.)，Reduce follow-up review costs。
Cost reference (charged based on project complexity)
CRS inquiries are usually based on “number of accounts”、Number of jurisdictions、Architecture level、Historical rectification workload、Comprehensive evaluation of “Bank Inquiry Rounds”。The following table is a reference for common cost components of corporate compliance projects (currency：HKD）。If it also involves license/compliance system construction (such as MSO/AML documents)，Can integrate CRS information with KYC/AML system，Reduce recurring costs。
| cost module | Reference project | Reference amount (HKD) | illustrate |
|---|---|---|---|
| Government fees (reference matrix) | Application | 3,310 | For reference regarding government fees in Hong Kong MSO application scenarios |
| Government fees (reference matrix) | Fit&Proper | 860/people | Based on the number of relevant personnel |
| Basic operations (reference matrix) | Company Reg | 8,000–15,000 | Basic cost range such as company registration/maintenance |
| Basic operations (reference matrix) | Office | 20,000–80,000/year | Office Space and Compliance Display Cost Range |
| Professional Services (Reference Matrix) | MSO service | 60,000–150,000 | Compliance/declaration support and other service areas (scenario-based reference) |
| Professional Services (Reference Matrix) | AML Docs | 20,000–80,000 | Institutional documents and manuals (scenario-based reference) |
| Comprehensive Compliance Budget (Reference Matrix) | Total（Standard） | 150,000–400,000 | Total range of common standard projects (adjusted depending on scope and complexity) |
Enterprises that need to prepare bank account opening and CRS materials simultaneously，Can be referenced：Hong Kong (HSBC/Standard Chartered/Hang Seng) account opening。Long-term solutions involving structure and asset allocation，Extensible：international tax planning、Wealth inheritance planning、Family office establishment。
FAQ：FAQ
The essence of CRS is a tax-related information exchange mechanism.，does not equate to automatic taxation。However, the information exchange will improve the tax authorities’ ability to obtain information on cross-border assets and income.，If the declaration is inconsistent or there are undisclosed matters，May trigger subsequent inquiries or audits。
You should first confirm your tax residency status and TIN acquisition rules.，Then prepare supporting documents that match your place of residence (address、Facts of residence、Employment/Operation、Identity change timeline, etc.)，And ensure that it is consistent with the account opening KYC and historical forms.。
Usually it is necessary to penetrate to the final natural person to control the person，combined with shareholding、control、Comprehensive judgment of directors/management control and other arrangements。We will output a structural diagram that can be understood by financial institutions、Control path and basis description。
Change itself is not negative，But the bank will require reasonable explanation and evidence support。It is recommended to complete the consistency check before submitting，and prepare “why change、when to change、"Based on what" description and attachments，Reduce the probability of account restriction。
Linkage is possible and recommended。Many risks come from inconsistent information caliber (for example, the actual management location、Nature of income、Personnel and office content, etc.)。Please refer to our BEPS compliance services：https://www.gxt-hk.com/beps-compliance-consulting/。
