Common CRS self-certification mistakes: claiming 'no tax residence anywhere', inconsistent residency across banks, ignoring beneficial-owner layers, outdated certs after moving, treating shell holdings as active NFEs, and mismatched CRS data vs declared income.
The seven: (1) 'No tax residence' answers — every individual has a residence for CRS purposes; claiming none flags the account. (2) Inconsistent self-certs across institutions — banks exchange data quality flags. (3) Wrong entity classification (active vs passive NFE) — passive entities get looked through to individuals. (4) Controlling-person omission — 25%+ shareholders must be listed even if 'not involved'. (5) Stale certificates after relocation — residency changes require re-certification. (6) Trust structures listed as corporate accounts without looking through to settlor/beneficiaries. (7) Declared income inconsistent with reported account flows — the data match that actually starts audits. Fix: annual self-cert review as part of compliance calendar.
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