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June 26, 2026

This guidance outlines the compliance obligations for UAE Reporting Financial Institutions (RFIs) regarding Citizenship by Investment (CBI) and Residence by Investment (RBI) schemes. Highlighting risks identified by the OECD, the document mandates that RFIs must not rely on self-certifications if they have reason to know the documentation is unreliable. It provides specific due diligence procedures, including high-risk jurisdiction analysis and mandatory follow-up questions regarding physical presence and tax filings in other jurisdictions. These measures ensure accurate tax residency identification and prevent the misuse of investment schemes to circumvent the Common Reporting Standard reporting requirements.

Common Reporting Standard ("CRS")

What Should be Included in CRS Reporting?

1. Background to the CRS

2. Impact of the CRS

3. Purpose of this Circular

4. What Should be Included in CRS Reporting?

4.1. Tax Identification Number (TIN)

4.1.1. New Accounts
4.1.2. Pre-existing Accounts
4.1.3. Quality of TIN Data Collected

4.2. Date of Birth

4.2.1. New Accounts
4.2.2. Pre-existing Accounts

4.3. First Name and Last Name
4.4. Address

Background to the CRS

The Common Reporting Standard ("CRS") for Automatic Exchange of Information has been developed by the OECD with an intention to cooperate in the global effort towards tax transparency. The UAE has signed the Convention on Mutual Administrative Assistance in Tax Matters ("Multilateral Convention"), the Declaration of Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information ("MCAA"), and the Unilateral Declaration in April 2017.

Reporting Financial Institutions ("RFIs") that maintain financial accounts are required to collect and report information on an annual basis related to CRS reportable accounts which is then exchanged with CRS exchange partner jurisdictions. The collection of account information aims to identify the jurisdictions(s) of tax residence for account holders and certain financial account information and to report this information to CRS exchange partner jurisdictions on an annual basis.

Impact of the CRS

Under the CRS, UAE RFIs are required to apply due diligence procedures and collect documentation to identify whether a financial account maintained by the UAE RFI is a CRS Reportable Account. As a result, individual and entity account holders are required to provide completed CRS self-certification forms and/or documentary evidence when requested by UAE RFIs, such as banks, upon account opening. The CRS self-certification form typically requires that the individual account holder declares their name, residence address, jurisdiction(s) of tax residence and TIN(s) (where applicable). Entity account holders are also required to disclose their name, address, jurisdiction(s) of tax residence and TIN(s) (where applicable) as well as information on Controlling Person(s) for certain types of entities.

It is the responsibility of UAE RFIs to ensure effective implementation of the CRS. UAE RFIs are required to ensure that they have effective systems in place to accurately identify CRS Reportable Accounts and to ensure that the information reported for CRS purposes meets the data quality requirements.

Contents

Background to the CRS

Impact of the CRS

Purpose of this Circular