CRS Agreement: Will the tax authorities find out about foreign accounts? Which institutions share information under CRS, and what data about you will the tax authorities receive?

The author of the article: Denis Korablyov

Modified date: 07 November 2025

If you have accounts in foreign banks, starting from the fall of 2024, the Ukrainian tax authorities will already be receiving data about them. This became possible thanks to the international CRS (Common Reporting Standard) agreement, which Ukraine officially joined in 2023.
About 120 countries, from Poland to offshore jurisdictions, are now exchanging information about non-residents’ bank accounts.
What does this mean for you personally?
The tax authorities will see not only the fact that an account exist, but also the total amount of all incoming transactions.
In this article, we will explain how the CRS system works, what risks arise from ignoring reporting requirements (including fines of up to 800,000 UAH), and most importantly – how to correctly determine your tax residency to avoid problems.

CRS Agreement: What data about you do the tax authorities receive

Do you have accounts in foreign banks? The Ukrainian tax authorities can now gain access to this information. How? Through the international CRS agreement signed back in 2023. What risks does this pose for you? And if the State Tax Service of Ukraine receives information about foreign accounts, is it then obliged to collect data on that person’s accounts in Ukraine and send it back in response? We answer all these questions in this article.

This happens even if you’ve completely forgotten about it – the process is already underway, and you can no longer influence it.

If you have citizenship, a permanent place of residence, and close ties with Ukraine, you are most likely considered a Ukrainian tax resident. For all other countries, you are, on the contrary, a non-resident.

For many people, the issue of tax residency may seem confusing. You can read more about this status in Article 14.1.213 of the Tax Code of Ukraine.

The United States, by the way, is not a CRS participant, but it has its own system – FATCA.

How does it work? Ukrainian banks are required to report to the U.S. about accounts belonging to U.S. citizens or U.S. tax residents. However, this exchange is one-sided: Ukraine provides information to the U.S., but data about Ukrainians’ accounts in American banks are not shared back. In other words, FATCA protects American tax residents – not the other way around.

What to do if two countries claim your tax residency status?

This is where the rules of double taxation avoidance agreements between countries come into play.
For example, if you have permanent residences in both countries or in neither, and it’s difficult to determine where your center of vital interests lies, the deciding factor becomes the country where you usually live.
If that still doesn’t clarify things, citizenship is taken into account.

In the context of CRS, financial institutions rely primarily on the data you provide in the self-certification form.
There, the account holder declares their tax residency – specifying their country of residence, tax identification number, etc.

In addition, banks use information collected under AML and KYC procedures.
So, if a person has lived in another country for some time and this is confirmed by documents and indicated in the self-certification, the country where the account was opened will likely not automatically transmit this data to the Ukrainian tax authorities.

Important to remember: providing false information in the self-certification form may lead to fines, the size of which depends on the specific jurisdiction.
In Ukraine, such a penalty can reach 100 minimum wages – in 2025, that’s about 800,000 UAH.

It’s also worth knowing that the self-certification document is filled out only when opening a new account.
If the account already exists, the financial institution determines your tax residency under CRS based on existing client data – such as your current address, mailing information, phone number, and other indicators that may suggest your residency status.

Therefore, before opening a foreign account or working with international banks, it makes sense to verify your tax residency status and prepare supporting documents.

If you still have doubts, it’s best to consult a tax expert to avoid the risk of large fines or unintended legal consequences.

What data is transmitted to Ukraine?

It’s actually quite simple: when you open an account in a foreign bank, you fill out a form indicating your first and last name, date of birth, address, country of tax residence, and taxpayer identification number.

This means that the Ukrainian tax authorities will see not only the fact that you have a foreign account, but also how much money has been credited to it.

And don’t try to deceive the bank! Ukrainian and European (and even non-European) banks distribute questionnaires asking you to specify your country of tax residence and taxpayer identification numbers in other countries. The exchange of information takes place specifically with the countries where you are a tax resident. If you lie to the bank, you risk a fine of about 800,000 UAH. Therefore, it’s best to consult with accountants or lawyers rather than experimenting with such schemes.

Which institutions share information under CRS?

Information under CRS is transmitted by so-called “reporting financial institutions.”
These include not only banks but also credit unions, payment systems, e-money issuers (such as Payoneer or Revolut), investment brokers, asset management companies, private pension funds, insurance companies, and even real estate financing funds.

So, if you have an account not only in a bank but also in a payment system or investment company, your data may also be transmitted under the CRS standard.

What happens if the tax authorities find out about foreign accounts?

The tax authorities may take interest in several things.

If the State Tax Service of Ukraine (STS) receives information about foreign accounts, is it then obliged to collect data on that person’s accounts in Ukraine and send it back in response?

The answer is no, this does not happen automatically. Under CRS rules, Ukrainian banks transmit information only about non-residents – that is, individuals who are not tax residents of Ukraine. So if you are a Ukrainian citizen and have opened an account in a Ukrainian bank, the STS does not collect or send your information abroad.

Therefore, if you don’t monitor your tax status, there’s a high chance that Germany will share information about your accounts in Ukraine, and Ukrainian authorities may, in turn, send your data back.

The situation is similar in Ukraine: if you haven’t provided documents proving that you’ve become a non-resident, banks will continue to treat you as a resident and include you in the reports for exchange.

Moreover, under CRS regulations, Ukrainian banks are explicitly allowed to involve third-party organizations to help identify clients with non-resident status.

For those receiving social benefits in Germany, this is a serious warning: if the Finanzamt or Jobcenter receives information about assets in your Ukrainian accounts, it could lead to unpleasant consequences – up to and including the loss of your benefits.