The OECD Issues An Updated CRS Implementation Handbook

The Organization for Economic Co-operation and Development (the "OECD") has published version 2.0 of its Common Reporting Standard (the "CRS") Implementation Handbook (the "Handbook"). Several of the changes will be of particular interest to high net worth individuals using trusts and other fiduciary structures globally for wealth planning purposes:

• Protectors – The OECD has confirmed that it expects Protectors to always meet the definition of "exercising ultimate effective control", and thus be Reportable Accountholders of Financial Institution ("FI") trusts, regardless of whether the Protector holds any powers or actual control. While appearing to contradict the plain language of the Model Commentary, it now seems clear that local authorities who adopt the OECD guidance will expect to receive information exchanged as to Protectors.