Personal bank account/private banking in non CRS / CRS countries for Canadian/European resident

[backpacker]

Can be done for non-residents but it's been getting more difficult lately. If you get some sort of residence permit, it's easy.

PH: No, can not be done with a reputable local bank anymore.
Even if you appear with an ACR-I-card which says "Tourist" you'll have a hard time. The branch might open an account and once you receive your first SWIFT (which goes through the banks' headquarter) you will get a one-month deadline to produce a residemce permit (a Tourist ACR is not a residemce permit!).

IIRC, @MiddleEuroAsia might be able to shed some light here. I'm not impressed by what I've seen but can't deny there seem to be opportunities.

EG: Read this (post #21) -> Investing in Georgia real estate
before boarding a plane.

Here is the CaRs country list and scheduled exchange date (April 2023)
https://www.oecd.org/tax/automatic-exchange/commitment-and-monitoring-process/AEOI-commitments.pdf

As expected: Armenia also joining CRS - Caucasus now under full control by OECD

 

[boy20hki]

Hello,

Based on your goals, I think your best options might be:

1. Setting up a UAE Free Zone Company (FZCO) alongside an EID (Emirates ID). This way, from the bank's perspective, you'd be considered a UAE resident and there would be no reporting for now. You could have regular transaction bank accounts for both you and your company ( a company account might take some time ~ 2-3 weeks).
2. Opening both personal and business bank accounts in Egypt. Many UAE banks have local branches in Egypt, and opening accounts there could be easier in some cases than in the UAE. Egypt is a cash-based society with money flowing in and out without major issues, but sometimes you might need to be creative with how things get done. HSBC is also an option, where you can get premier status for just $24k, compared to HSBC Singapore, where you'd need to maintain a balance of $200k+ for the same status, but you need the right connection whether in Egypt or the UAE, as the reality on the ground can differ significantly from what is stated in the laws. so keep that in mind.

In summary, a UAE FZCO coupled with a couple of Egyptian banks (an off-the-beaten-track place to keep some money hidden) should set you up nicely.

Good luck!

This sounds like a great option esp. the Egypt & UAE banks connection. So just want to confirm again:

+Just have that UAE setup and visit UAE 1 day every 6 months to keep UAE residency status, then UAE will not report any of my UAE bank account (both personal + company account) to Canada, right?
+If I will stay and be tax resident of Canada (183 days rule), would staying in UAE for 90 days per year to get UAE tax residency status offer any extra value? I guess probably not?
+And to keep UAE residency status while living most of the time in Canada, do I need to rent an apartment in UAE whole year around? How to save this unnecessary cost? Maybe just rent a UAE place for short term like 2-3 months and get the utility bill and use that to register foreign bank account and EMI is okay, then even in those non-CRS country my personal account would have UAE address and if they ever report they will report to UAE, not Canada ?

 

[Forester]

even in those non-CRS country my personal account would have UAE address and if they ever report they will report to UAE, not Canada ?

Financial institutions in countries being involved in CRS should primarily report to the country of the tax residence (which should be checked while onboarding); if they are aware about your residence country, they should report there as well (but this mechanism is not completely clear to me as in this case they do not have your TIN).
Another questions of you should be answered by somenone having good knowledge of UAE-related issues... (Nevertheless, I guess that having the tax residence in UAE should be beneficial )

 

[boy20hki]

Financial institutions in countries being involved in CRS should primarily report to the country of the tax residence (which should be checked while onboarding); if they are aware about your residence country, they should report there as well (but this mechanism is not completely clear to me as in this case they do not have your TIN).
Another questions of you should be answered by somenone having good knowledge of UAE-related issues... (Nevertheless, I guess that having the tax residence in UAE should be beneficial )

This was confirmed by a post in 2021: So yes, UAE does not report those accounts of UBO with Emirates ID.
UAE free zone - anonimity

I think in this case, both UAE FZCO and US LLC do not report to Canada under CRS/FATCA. If Canada finds out, well then the consequence is the same for both because Canada has CFC rule for tax resident: they will tax both in the same way

Form T1134 ID is a mandatory annual filing for Canadians who own more than 10% of a foreign corporation. Opening a company in another country triggers Canada's foreign affiliate regime and requires a disclosure annually to CRA and sometimes an income inclusion based on the profits of the foreign corporation. If you own, operate, and manage the company within Canada but trade/sell in the US. Your business is a Canadian resident.

If I keep all money in the company bank account of UAE FZCO / US LLC then UAE or US are both equally suitable option.
But if I want to do distribute from companies account big amount to any non-CRS countries's personal bank accounts like Egypt, Cambodia then having UAE tax residency (aka choose UAE FZCO over US LLC) will help out a lot as I will have the legit tax return in UAE to show that I pay personal income tax in UAE & the money transfer is legal, and avoiding having to show Canadian tax return which could pose some risk of being reported even thought they are non CRS banks and risk of being suspected of undeclared income. In this situation then having to live in Canada for 6+ months and UAE 3 months is the expected "lifestyle".

 

[Forester]

This was confirmed by a post in 2021: So yes, UAE does not report those accounts of UBO with Emirates ID.
UAE free zone - anonimity

Really an interesting discussion between @Fred & @Gediminas, thanks for pointing at it. All their posts worth reading, IMO.
It's only necessary to check whether after two years it still describes the situation well – as you have just done

I think in this case, both UAE FZCO and US LLC do not report to Canada under CRS/FATCA. If Canada finds out, well then the consequence is the same for both because Canada has CFC rule for tax resident: they will tax both in the same way

If I keep all money in the company bank account of UAE FZCO / US LLC then UAE or US are both equally suitable option.
But if I want to do distribute from companies account big amount to any non-CRS countries's personal bank accounts like Egypt, Cambodia then having UAE tax residency (aka choose UAE FZCO over US LLC) will help out a lot as I will have the legit tax return in UAE to show that I pay personal income tax in UAE & the money transfer is legal, and avoiding having to show Canadian tax return which could pose some risk of being reported even thought they are non CRS banks and risk of being suspected of undeclared income. In this situation then having to live in Canada for 6+ months and UAE 3 months is the expected "lifestyle".

Yes, my perception of the situation is the same; it was the background for my statement “I guess that having the tax residence in UAE should be beneficial”. (BTW, the personal income tax in UAE is zero, AFAIK.)

 

[PinkCat]

About the 3 months you have to be in UAE to be tax resident, how do they check that if at all? What I'm asking I spend there few weeks every year anyway, but can it be gamed so that looks like 3 months?

 

[Ivkide]

What is your current residency and passport? Can share some contacts in Africa.