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Golden passports or visas can create the potential for fraudulent CRS reporting.

23/11/2023

In 2018 the OECD advised that Residence and citizenship by investment (CBI/RBI) schemes, often referred to as golden passports or visas, can create the potential for misuse as tools to hide assets held abroad from reporting under the OECD/G20 Common Reporting Standard (CRS).

In particular, Identity Cards, residence permits and other documentation obtained through CBI/RBI schemes can be abused to misrepresent an individual’s jurisdiction(s) of tax residence and endanger the proper operation of the CRS due diligence procedures.

Therefore, and as part of its work to preserve the integrity of the CRS, the OECD has published the results of its analysis of over 100 CBI/RBI schemes offered by CRS-committed jurisdictions, identifying those schemes that potentially pose a high-risk to the integrity of CRS.

Potentially high-risk CBI/RBI schemes give access to a low personal tax rate on income from foreign financial assets and do not require an individual to spend a significant amount of time in the jurisdiction offering the scheme.

In 2018, Such schemes are currently operated by

  • Antigua and Barbuda, The Bahamas, Bahrain, Barbados, Colombia, Cyprus, Dominica, Grenada, Malaysia, Malta, Mauritius, Monaco, Montserrat, Panama, Qatar, Saint Kitts and Nevis, Saint Lucia, Seychelles, Turks and Caicos Islands, United Arab Emirates and Vanuatu.

In 2023, several countries offer Golden Visa programs. These programs allow foreign nationals to gain permanent residence and/or citizenship in a country in exchange for making an investment in that country. Here are some [not all] of the countries that offer Golden Visa programs:

  1. Portugal: Portugal is one of Europe’s top Golden Visa countries, with five investment routes currently on offer. The program has undergone major changes, but remains fully open.
  2. Anguilla: The beautiful Caribbean island of Anguilla can grant you a Golden Visa when you make a mere $150,000 investment in a government-controlled fund.
  3. Antigua and Barbuda: This Caribbean country also offers a Golden Visa program
  4. Austria: Austria is one of the European countries that offer a Golden Visa program.
  5. Bulgaria: Bulgaria, another European country, also offers a Golden Visa program
  6. Canada: Canada offers a Golden Visa program
  7. Germany: Germany is one of the European countries that offer a Golden Visa program
  8. Greece: Greece, another European country, also offers a Golden Visa program
  9. St Kitts: This Caribbean country also offers a Golden Visa program
  10. St Lucia: St Lucia, another Caribbean country, also offers a Golden Visa program
  11. Turkey: Turkey offers a Golden Visa program

For more go to

Together with the results of the analysis, the OECD published a practical guidance (see Frequently Asked Questions section)

the FAQs  will enable financial institutions to identify and prevent cases of CRS avoidance through the use of such schemes. In particular, where there are doubts regarding the tax residence(s) of a CBI/RBI user, the OECD has recommended further questions that a financial institution may raise with the account holder.

Moreover, many jurisdictions have committed to spontaneously exchanging information regarding users of CBI/RBI schemes with all original jurisdiction(s) of tax residence, which reduces the attractiveness of CBI/RBI schemes as a vehicle for CRS avoidance.

Going forward, the OECD will work with CRS-committed jurisdictions, as well as financial institutions, to ensure that the guidance and other OECD measures remain effective in ensuring that foreign income is reported to the actual jurisdiction of residence.

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