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Podcast: Offshore Tax with HTJ.tax
Episode: Hong Kong vs Switzerland: Look-Through Rules for Trust Equity Interests
Description: This episode explores how different jurisdictions interpret the CRS look-through rules for trusts that qualify as Reporting Financial Institutions (FI-trusts)—and why the divergence between Hong Kong and Switzerland matters.At the centre of the debate is a simple but technical question:When an equity interest in an FI-trust is held by an entity, must the trust always look through that entity—even if it is itself a Financial Institution?📘 The CRS & Implementation Handbook BaselineUnder the CRS Implementation Handbook issued by the Organisation for Economic Co-operation and Development:• Equity interests in an FI...