CRS/FATCA from Puerto Rico to UAE

[khila]

Dear community,

I have a company registered in UAE for which I use a bank account opened in Puerto Rico. I wish to continue using this account without reporting in UAE. However I'm having some doubts and I'd be appreciating it if you could be giving your thoughts on the matter.

As I'm seeing it Puerto Rico isn't participating in exchange under CRS (being unincorporated territory of the USA). From the FATCA perspective also there should not be an automatic exchange, as the agreement between the USA and UAE doesn't specifically mention sending information from the USA, so exchange would be happening in only one direction - towards the USA.

Only the risk of personal initiative by the bank is remaining?
But how likely is it to expect such a thing? Am I missing any other points?

 

[OffshorePhantom]

The FATCA agreement between USA and UAE is not bilateral so no information is exchanged from USA to UAE currently.
This is different from Germany, France, Spain, Italy & many others where individual accounts that earn more than $10 in dividends are reported, while companies account not.
For a UAE resident, reading the FATCA agreement, seems not even individual accounts are reported.

Even if accounts are not reported I do not suggest having a company in UAE and continuing to do business with it without reporting to the local authorities because sooner or later they may discover something.
In addition every year you have to declare false information that you are not earning anything with the UAE company to local authorities (not so wise in my opinion).

If you want to play this game at least use some other foreign companies like a US LLC. Even in that case in order to be on the safe side my suggestion is to hire a manager for the LLC who is resident in a tax-free or territorial tax country so that the US LLC is effectively managed from there and does not create a permanent establishment in UAE and thus being affected by the new 9% CIT.

 

[Clank]

As far as I know Puerto Rico doesn't participate in FATCA or CRS.

By the way, which bank are you using?

 

[Legal]

As far as I know Puerto Rico doesn't participate in FATCA or CRS.

By the way, which bank are you using?

Some Puerto Banks have MSB licenses in Canada, and it can be tricky.