Global reporting and why Georgia is one of the last honest answers
Since 2017, a quiet mechanism has fundamentally changed the rules of international wealth management: the Common Reporting Standard (CRS). Every year, banks, brokers and fund managers in more than 100 countries automatically forward account data to the tax authorities — without any application, court order or advance warning to the account holder. Account balance, interest, dividends, proceeds from securities sales, address, tax identification number: it all travels to wherever the person in question is tax resident.
The question wealthy savers have asked ever since is: how do you get out? The honest answer disappoints everyone selling discretion: you do not get out by choosing a bank. The only lever is tax residency.
What CRS actually reports
A German tax subject holding an account in Singapore is reported from Singapore to Germany. A French national with a Portuguese savings account: from Lisbon to Paris. The reported file contains name, address, tax ID, account number, year-end balance as well as all income — interest, dividends and disposal proceeds.
Anyone who believes they can escape reporting through a company or foundation in a non-CRS country is usually mistaken. For passive structures the so-called look-through principle applies: the bank looks behind the shell and reports the beneficial owners.
The US gap — and why it is irrelevant for most
The USA never signed CRS. Instead they operate FATCA — a system that works only in one direction: foreign banks report US persons to the IRS. The reciprocity Washington promised remains non-binding. That makes the USA the largest leak in the global reporting network — the Tax Justice Network ranks it first on the 2025 Financial Secrecy Index, ahead of Switzerland and Singapore.
In practice this means: anyone who is not a US citizen or resident can hold US assets with significantly less automatic disclosure to their home country. The tax liability in the home country remains unaffected — only the automatic transparency changes, not the legal obligation.
Georgia: CRS member since 2025 — and still relevant
Note: Georgia joined as a full CRS member in 2025. This means: foreign accounts of Georgian tax residents are automatically reported to Georgia — no longer to the old home country.
That is precisely the argument. Anyone with tax residency in Georgia has their foreign accounts reported to Georgia — no longer to the old home country. The Georgian tax office sees the data but has no tax claim on correctly classified foreign income. The data stream runs into the void.
29 countries worldwide do not, in principle, tax foreign income — through pure territorial systems, remittance rules or time-limited exemptions. Georgia belongs to this group and combines it with a remarkably clear tax system:
- 0% on foreign income when correctly classified as non-Georgian source
- 20% flat rate on Georgian employment income
- 1–20% corporate taxation depending on the chosen regime
This is not a hiding place from the system, but a country of residence that sits fully inside the system — and still has no tax grip on foreign income. The transparency is complete. The tax liability is not.
What genuine residency means
Residency on paper is not enough. Like most countries, Georgia applies substance tests and day-count rules. The 183-day threshold is a guideline, but not a free pass. Anyone changing tax residency must be able to prove it: through actual presence, tenancy agreements, accounts, social ties.
The people who navigate CRS well treat it as a given fact of the system and choose a residency they can defend — with documents, with days, with lived everyday life. Those who fail have treated a foreign account as a hiding place.
What comes next
The Crypto-Asset Reporting Framework (CARF) mirrors CRS for digital assets. Crypto exchanges and custodians in 48 countries began collecting data on 1 January 2026; the first reports are due to flow in 2027. The UAE has signed CARF, with first exchanges planned for 2028. There, no local tax assessment will no longer mean: no report to the home country.
For persons resident in Georgia, full CRS membership means that the Georgian tax authority actively receives data about their foreign accounts. Anyone using the territorial tax system should ensure that income is cleanly classified and documented as non-Georgian source — because the transparency is mutual and complete.
We can help you both with setting up a US LLC and with Georgia (Sakartvelo) residencies.
This article is for general information only and does not constitute tax or legal advice.
