Cross-border wealth planning is becoming increasingly transparent.
For global families holding bank accounts, investment vehicles, companies, trusts and digital assets across multiple jurisdictions, the challenge is no longer simply where assets are held. It is also whether tax residency, beneficial ownership and financial reporting records remain accurate and consistent across jurisdictions.
In 2026, this issue is becoming particularly important as jurisdictions prepare for the amended OECD Common Reporting Standard, often referred to as CRS 2.0, and the Crypto-Asset Reporting Framework (CARF). At the same time, beneficial ownership regimes continue to evolve across the European Union and Switzerland.
The first exchanges under the amended CRS and CARF are expected to begin from 2027 in participating jurisdictions, making 2026 an important preparation period for international families and family offices.
1. CRS 2.0: Expanding Financial Account Transparency
The Common Reporting Standard has formed the foundation of international automatic exchange of financial account information for more than a decade.
The amended CRS expands and clarifies this framework to reflect changes in financial products and cross-border ownership structures.
Among the important developments are broader coverage of certain electronic money products and central bank digital currencies, together with more detailed reporting concerning the roles of controlling persons associated with legal entities and trusts.
For individuals with connections to multiple jurisdictions, the amended framework also makes accurate tax residency self-certification increasingly important.
This does not mean that tax treaty tie-breaker rules have disappeared. Rather, tax residency under a Double Taxation Agreement and reporting obligations under CRS are separate issues that need to be evaluated carefully.
For global families, inconsistent tax residency information submitted to different banks or financial institutions can therefore create unnecessary compliance risks.
2. CARF: Bringing Crypto Assets into Automatic Tax Reporting
Digital assets have historically existed outside much of the traditional financial account reporting infrastructure.
The OECD’s Crypto-Asset Reporting Framework (CARF) is designed to address this gap.
Under CARF, in-scope Reporting Crypto-Asset Service Providers may be required to collect tax residency information and report relevant crypto-asset transactions conducted for or on behalf of users.
The framework can capture activities such as exchanges between crypto assets and fiat currencies, exchanges between relevant crypto assets and certain transfers, depending on the applicable rules.
Importantly, CARF should not be interpreted as meaning that every decentralized protocol or self-hosted wallet automatically becomes a reporting entity. The precise obligations depend on the nature of the service provider and how participating jurisdictions implement the framework domestically.
For family offices with meaningful digital-asset exposure, this means crypto holdings should increasingly be considered alongside traditional banking and investment accounts when reviewing cross-border tax reporting.
3. Beneficial Ownership Registers Are Also Evolving
Automatic financial reporting is only one side of the transparency landscape.
Governments are simultaneously strengthening mechanisms designed to identify the Ultimate Beneficial Owners (UBOs) behind companies and other legal structures.
European Union
The EU’s evolving anti-money laundering framework continues to strengthen beneficial ownership transparency while balancing access to ownership information against privacy rights.
Following European court decisions restricting unrestricted public access to beneficial ownership information, the framework provides access for competent authorities and obliged entities while also establishing mechanisms for certain persons or organizations with a legitimate interest, including qualifying journalists and civil society organizations.
For international families using multi-layer corporate structures, this increases the importance of maintaining consistent ownership information across corporate registries, financial institutions and tax filings.
Switzerland
Switzerland is also moving toward a centralized beneficial ownership transparency framework.
The Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (LETA) is scheduled to enter into force on October 1, 2026, alongside related anti-money laundering reforms. The framework introduces a federal register designed to improve authorities’ ability to identify the beneficial owners behind legal entities.
Unlike a public corporate directory, the Swiss framework is designed primarily as a regulatory and enforcement tool rather than an unrestricted public database.
4. What This Means for Global Families
These developments do not eliminate legitimate international wealth structures. Companies, trusts, foundations, investment funds and holding vehicles continue to serve important purposes in succession planning, asset management and cross-border investment.
What is changing is the level of information consistency and transparency expected across those structures.
A family might, for example, maintain tax residence in one jurisdiction, hold investment accounts in another, own assets through a holding company elsewhere and use a trust or foundation for succession planning.
Each arrangement may be perfectly legitimate. However, problems can arise when banks, corporate registries, trustees and tax authorities receive conflicting information regarding who owns or controls the assets and where those individuals are tax resident.
The compliance priority is therefore increasingly about consistency rather than complexity.
5. Key Compliance Priorities for 2026
For global families and family offices, several areas deserve particular attention ahead of the next phase of international reporting requirements:
Review tax residency records.
Confirm that Tax Identification Numbers (TINs), addresses and residency declarations supplied to banks, fund administrators and other financial institutions remain accurate.
Reconcile beneficial ownership information.
Review companies, trusts, foundations and holding structures to identify discrepancies between legal ownership, beneficial ownership and controlling-person records.
Include digital assets in compliance reviews.
Crypto holdings and transactions should no longer be treated as completely separate from the family’s broader tax reporting and governance framework.
Review cross-border structures for genuine purpose and substance.
International structures should have a clear legal, commercial, investment or succession rationale and comply with applicable economic substance and tax rules.
Strengthen data governance.
Greater regulatory transparency also means more sensitive family information is being collected and stored. Cybersecurity, access controls and confidentiality therefore become increasingly important components of family office governance.
Conclusion: Transparency Is Becoming Part of Wealth Governance
CRS 2.0, CARF and expanding beneficial ownership frameworks reflect a broader direction in international regulation: cross-border ownership and financial activity are becoming more visible to tax and regulatory authorities.
This does not mean global families must abandon international investment structures. Instead, it increases the importance of ensuring that those structures are legally defensible, accurately documented and consistently reported.
For family offices, 2026 is therefore less a deadline than a preparation year. Reviewing tax residency records, beneficial ownership disclosures, digital assets and entity structures now can help reduce reporting inconsistencies as the next phase of automatic information exchange begins from 2027.
For complex multi-jurisdictional structures, tax and legal implications should be reviewed with qualified advisers in each relevant jurisdiction.
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