For family offices and fiduciaries, tax transparency has long been routine. Every account opening requires self-certifications, every structure a classification, and errors often surface years later when a tax authority asks. 2027 brings two changes: Switzerland’s switch to FATCA Model 1 and, at the earliest, automatic exchange of information on crypto-assets. This article sets out the three regimes. It does not replace tax advice.
Three regimes, one goal
Automatic exchange of information under the OECD Common Reporting Standard covers financial accounts of persons tax-resident in partner states. FATCA is the US counterpart for US persons. The CARF extends exchange to crypto-assets passing through crypto service providers. All share one principle: financial institutions identify clients’ tax status and report to the tax authority, which passes the data on.
The real work: classifying the structure
In family structures, the classification of each entity decides everything else. A company, foundation or trust can itself be a reporting financial institution, for example as an investment entity if professionally managed and investing mainly in financial assets. Or it is a passive entity whose controlling persons are reported by the account-holding institution. For trusts, controlling persons typically include settlor, trustees, protector and beneficiaries, similar to the information on Form T.
For a private trust company or a professionally managed family foundation, this can mean carrying reporting duties itself, with registration and its own due diligence. That question should be settled when a structure is set up, not at a bank’s first query.
FATCA: the switch to Model 1
Switzerland has so far implemented FATCA under Model 2: Swiss financial institutions report directly to the US tax authority with US clients’ consent; without consent, group requests run via administrative assistance. With the agreement of 27 June 2024, Switzerland moves to Model 1, with reciprocal automatic exchange via the tax authorities. According to planning, the switch takes effect on 1 January 2027. For structures with US beneficiaries or US family members, this is a good occasion to review the FATCA classification of every entity.
CARF: crypto-assets
Parliament approved the legal basis for AEOI on crypto-assets on 26 September 2025. According to the State Secretariat for International Finance, it will be implemented from 1 January 2027 at the earliest. Anyone holding crypto-assets in family structures should document which providers they pass through and which tax residences are affected.
AEOI and AML law are not the same
Controlling persons under the CRS and beneficial owners under AML law overlap but are not identical. Thresholds and terms differ, and a bank collects both separately. Recording the information cleanly once per mandate, with roles, tax residences and history, answers both questions from the same source.
What family offices should do now
- Record for each structure how every entity is classified under CRS and FATCA, with reasoning and date.
- Keep tax residences and US status of all persons involved current, especially after moves, marriage or inheritance.
- Review structures with a US connection before the 2027 FATCA switch.
- Document crypto-assets and their providers.
- Agree classifications with tax advisers and recheck when the structure changes.
Systems
In many family offices the data for AEOI, FATCA and AML sits in separate spreadsheets. FLIORE keeps people, roles in companies, trusts and foundations and the related documents per mandate in one place, so the information stays consistent across all three regimes. Thresholds for beneficial owners in other countries are shown in our UBO threshold overview.