Yeah, pretty much agree with Artemis. It leads to nowhere.
What if countries that get the wrong
CRS report start to complain back to the banks?
It's still a valid question so let's speculate "what if". What if a CRS amendment is made with a new requirement imposed on receiving country to report back to a foreign Financial Institution about non-resident status?
First, it's an asymmetrically costly move, and immediately, the no-tax countries would have leverage over high tax communist bungholes to ask for direct compensation for administrative work.
Assuming the amendment gets implemented anyhow:
1. The bank deems your current residency invalid and asks you to re-certify for the purpose of CRS. You say that to the best of your knowledge, you have no other (tax) residencies at this point. The bank closes your account because the risk is higher. You transfer your funds to another account.
2. The same as above, but the bank also takes a shot from the hip and relays a CRS report you to your country of birth (
citizenship), just in case. So what? You're registered as non-resident in your country of birth as well.
What other mean things can they do? You live in Country C and they have no documentation that links you to Country C. If they close the account, it's not the end of the world either. If you're a landlord in your proxy residency country (although registered as non-resident), you can keep opening new accounts in other banks or other countries with your recent Proof of Address document (utility bill) at any time you see fit.
Can your proxy residency country fine you for doing so? At worst, they can invalidate your ID, but you can threaten to "liquidate your property
investments xD". PS! You can open a domestic
bank account in your proxy residency country using your proxy residency documents, with a legitimate connection to country as a property investor. You need to collect rent from your property investment. What leverage do they have to close this domestic account that has a legitimate requirement to exist? After all, the property taxes and local rental income taxes are paid.
And lastly, what laws would the Financial Institution break if they let you keep your account if the documents are valid? They know you do not
pay income tax in your CRS report destination country, or in any other country, yet they have all the documents the laws ask them to collect in regards to CRS. Is there a risk of getting fined for accepting clients that do not pay income tax anywhere? If yes, what about those poor corrupt sell-out politicians who now live in
Monaco?