CRS and Georgia — what your home tax authority sees (and what it does not)

CRS — the OECD’s Common Reporting Standard — is the global sister of FATCA. Since 2017 it powers automatic tax-information exchange between 110+ states. Georgia implemented the standard in 2023; the first automatic exchange ran in September 2024 — annually since. What does that mean in practice?

What CRS does — in short

Every Georgian bank reports once a year (to the Revenue Service by June 30; the exchange with partner states runs in the September cycle):

• Account existence (IBAN, opening date)
• Balance as of Dec 31 of the prior year
• Gross income of the year (interest, dividends, other earnings)
• Account holder data including the tax-identification number

The data goes to the Georgian Revenue Service which forwards it automatically to the tax authority of the tax-residence country — so for a German tax resident, to the Bundeszentralamt für Steuern.

What CRS does NOT do

• No transaction-level transfer

  Your home authority does NOT receive a list of individual transfers. Only balances + aggregates.

• No third-party access

  Debt collectors, private detectives, credit bureaus see nothing. It is a state-to-state flow, not an open register.

• No automatic prosecution

  A CRS report alone does not trigger a case. Only when the aggregate does not match your filing does the tax office investigate.

• No real-time visibility

  CRS data is ~12 months old when your home authority processes it. There is no live monitoring.

Practical consequence

How to declare

For DE tax residents with a GE account or LLC:

1. Anlage AUS of the income-tax return — foreign income, Georgia line
2. Tax treaty offset of the 1% or 15% paid in Georgia against the German liability
3. Check German CFC / exit-tax rules: CFC taxation (§§ 7 ff. AStG) only applies with a controlling stake (> 50%), passive income and low taxation; the 1% threshold relates to the exit tax (§ 6 AStG) on relocation — we deliver the certificates

If you are our client: we generate the offset-eligible certificates annually and send them to your German tax advisor by March 31.

CRS 2.0 — and the real lever

Since 1 January 2026, CRS 2.0 extends the standard to e-money products, CBDCs and indirect crypto holdings. Transparency keeps increasing — not decreasing.

One more thing matters: CRS reports accounts of people who are tax-resident in a different country. If you genuinely move your centre of life to Georgia and become tax-resident there, your Georgian accounts are not reported abroad — not through tricks, but because there is no foreign recipient jurisdiction anymore. Until then: declare correctly.

Verdict

CRS is not a “tax-haven killer” — it is a transparency mechanism that enforces exactly what we recommend our clients do anyway: structure cleanly, declare correctly, legally use the lower rates.

If you can live with CRS, you can live with Georgia. If you can’t, this isn’t the right direction.