I don't agree here. If a bank decides to CRS you based on your passport, the fact that you don't live in your country may not help you. Your tax office will ask you where are you paying your taxes then? Where is your center of business? If the answer is, I live in Thailand but I don't pay taxes there, your tax office may consider you tax resident of your home country and good luck proving to them otherwise. It may depend from country to country, but in my case (Russia), there are legal docs that explicitly say that you have to pay taxes at home in case you don't pay taxes elsewhere and living outside of the country is not enough to be off the hook. I suspect other high income tax countries may have the same approach. You didn't say "John" is tax resident in Thailand right? But in this case you have to look for non CFC country and get a tax residency there which is not as easy as just get a Dubai residency and enjoy 0% taxes
BTW
@Fred can you comment on this?
Economic substance regulations in the UAE
Do Dubai banks do ESR?
There are some things like "Calculation of full-time equivalent employees and operating expenditure in relation to Relevant Activities" etc