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Podcast: Offshore Tax with HTJ.tax
Episode: Where Switzerland Misinterpreted the CRS Implementation Handbook
Description: 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 clarifies that the CRS defines the following...