CRS and banking secrecy: what has changed since 2017

The CRS , or Common Reporting Standard, put an end to offshore banking secrecy as it existed. Since 2017, the automatic exchange of tax information between countries has been the norm. Understanding how it works is essential for anyone considering relocation: it's what distinguishes a sound tax break from a risky situation.

The end of an era

For decades, banking secrecy relied on opacity. A foreign bank transmitted little or nothing to the tax authorities of its client's country of residence. Those days are over.

Before and after 2017

Previously, an account held abroad could remain invisible to the tax authorities of the country of residence. Information exchange existed, but only upon request, on a case-by-case basis, and slowly.

Afterwards: the exchange became automatic, systematic, and annual. The shift occurred for France starting in 2017. Offshore banking secrecy as it was conceived no longer exists.

What is the Common Reporting Standard?

The CRS is a global standard for the automatic exchange of tax information between States, developed under the auspices of the OECD.

An OECD standard

More than one hundred jurisdictions participate. The principle is to standardize what banks collect and transmit, so that information can circulate between administrations without prior request.

More than 100 participating countries

The network covers most financial centers. The major traditional centers of banking secrecy have joined the system. A few jurisdictions do not participate, or only partially — but this has become the exception, not the model.

In concrete terms, who transmits what?

The mechanism is simple to describe.

The data exchanged

Your bank abroad identifies your declared tax residence. Once a year, it transmits information about your accounts—balances, interest, dividends, and proceeds from sales—to the tax authorities of that country.

Frequency and recipient

The exchange is annual. The recipient is the tax authorities of the country where you are declared a tax resident. This last point is crucial: everything hinges on the consistency between your declared residence and your actual residence.

What the CRS is changing for a relocation

This is where the CRS becomes central to a departure strategy.

The case of the poorly informed French resident

If you are a French tax resident and hold an undeclared foreign bank account, the French tax authorities are automatically notified. The account is no longer hidden. The information arrives automatically, every year.

This marks the end of the strategy of opacity. It no longer works. It exposes.

The case of the properly structured non-resident

For a person who has been properly relocated, the CRS makes no difference — and that is precisely the objective.

Once you are a tax resident of your new jurisdiction and a non-tax resident of France, the information transmitted by your local banks is generally sent to the authorities of your country of tax residence. The CRS data flow then becomes consistent with your situation.

Transparency is only a risk in inconsistent situations. For a properly established tax break, it is neutral.

Why the strictness of the tax break has become decisive

The CRS has shifted the focus of the relocation. Yesterday, some were banking on discretion. Today, only solidity matters.

Transparency makes inconsistency visible

An undocumented residence is no longer hidden. CRS (French immigration law) data automatically feeds into the country to which it is directed. If that country is France because the tax evasion is questionable, the financial data is used to build a tax reassessment case—without any investigation having been necessary.

In other words: the CRS transforms a fragile tax break into an active risk. And it makes a solid tax break fully defensible.

Consistency as the new standard

Mastering international taxation after 2017 is no longer about concealment. It's about constructing a situation where every element—residence, accounts, flows, declarations—is consistent with the others. That's precisely what our method aims for.

Non-participating states: a false good idea

Some jurisdictions do not participate, or only minimally, in the CRS. There is a temptation to use this as an argument.

This is an analytical error. A state's non-participation in the CRS does not create a right to opacity vis-à-vis France. It does not modify the rules of tax residency. It does not eliminate the obligation to declare income.

Building a relocation strategy around a lack of information sharing is like building on sand. Legal compliance remains the only sustainable standard. A situation can incorporate this reality as one factor among others—never as the core of the strategy.

Building a situation in line with the era of transparency

Aligning actual residence and bank flows

The transfers between your French and local accounts must be consistent with your declared tax situation. Any inconsistency in these transfers is immediately apparent. Organizing these transfers should be done from the outset.

Maintaining consistency over time

The CRS transmits data annually. A compliant situation in the first year must remain so in subsequent years. This sustained consistency is the focus of our post-installation support .

Transparency is not the enemy of relocation.

This is the key reversal to understand. The CRS (French riot police) didn't close the door to relocations. It closed the door to poorly planned relocations.

For those who establish a real residence, organize their flows coherently and respect their obligations, transparency is a neutral framework — even an asset, since it makes the situation demonstrable.

Bank secrecy is dead. Legal, documented, and consistent tax planning has never been more effective. Assessing the strength of your situation against the CRS is a step that Coreway incorporates from the outset of the analysis.