UK and International Tax news

Update To Citizenship And Residence By Investment Schemes

Tuesday 4th December 2018

The OECD has issued a further update on its assessment of jurisdictions which offer ‘residence by investment’ or ‘citizenship by investment’ schemes which can be used to circumvent reporting under the Common Reporting Standard.

The OECD has confirmed that it has been working closely with Panama to ensure that any risks created by its RBI programmes are effectively addressed. As a result of that work in relation to Panama’s Reforestation Investor Permit, Economic Solvency Permit and Friendly Nations Permit programmes, under each of these programs, Panama ensures that residence documentation provided to successful applicants is identified as issued under the relevant programme.

The OECD has now updated its guidance for financial institutions on CBI/RBI schemes to state that, where residence documentation clearly identifies the programme under which it was issued, only such specific residence documentation, should be perceived as potentially high-risk in the context of the CRS due diligence procedures. When presented with such documentation, financial institutions may consider applying the enhanced CRS due diligence procedures, in order to ensure that the documentation is not misused by account holders for the purpose of circumventing the CRS. In other cases, Panama-issued residency documentation is not by itself to be treated as being potentially high-risk from the perspective of the CRS due diligence procedures.


The OECD guidance will be updated on an ongoing basis where other jurisdictions adopt effective mitigating measures.

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