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Common Reporting Standard: What Aussie Expats Must Know

Nov 2018 7 min read By Shane Macfarlane CA
Common Reporting Standard: What Aussie Expats Must Know

Update: This article was originally published in November 2018. Substantially rewritten and updated in June 2026 to reflect current penalty amounts, CRS developments and the new crypto-asset reporting rules.

Overdue Australian Tax Returns? The ATO Already Knows Where You Bank (and Soon, Where You Keep Your Crypto)

Let me paint you a picture. You moved overseas a few years back. Life got busy. The Australian tax returns slipped, first one year, then three, then you stopped counting. And somewhere in the back of your mind lives a comforting little voice that says: “She’ll be right. I’m on the other side of the world. How would the ATO even find me?”

I’m here to evict that little voice, because it’s about a decade out of date.

Once upon a time, it had a point. The ATO knew you’d left the country (your passport records told them that much), but they didn’t know where you’d landed, where you banked, or what you earned. Chasing expats was expensive guesswork, and tax information agreements only let them ask another country about you if they already had a concrete reason to. No fishing expeditions allowed.

Then came the Common Reporting Standard, and the fishing expedition became an all-you-can-eat buffet, delivered to the ATO’s door every single year.

What is the Common Reporting Standard, in plain English?

The short version: it’s a global dob-in scheme for banks.

The slightly longer version: after the United States introduced its FATCA regime in 2010, forcing foreign banks to report on American account holders, the OECD (now a club of 38 member countries) built a worldwide equivalent at the G20’s request. Under the CRS, banks and financial institutions in participating countries must identify which of their customers are tax residents of other countries, and report those customers’ account details to their local tax authority. That authority then automatically ships the data to the customer’s home tax office, every year, without anyone asking.

So your bank in Singapore, London, Dubai or Hong Kong tells its tax authority about you, and that tax authority tells the ATO. Automatically. Annually. Whether you’ve done anything wrong or not.

When the original version of this article was written back in 2018, the ATO had just received its very first CRS data drop and around 100 jurisdictions were getting started. Today, well over 100 jurisdictions exchange information automatically every year, covering virtually every country an Aussie expat is likely to bank in. This isn’t a new net being rolled out anymore. It’s a mature, well-oiled machine, and the ATO has had the better part of a decade to get very good at using it.

What exactly gets reported to the ATO?

More than most people expect. For each reportable account, the ATO typically receives:

Your name, date of birth, address and tax identification details. The name of the financial institution and your account number. Your account balance at the end of the reporting period (or at closure). And the income flowing through the account: interest on deposit accounts, dividends and other investment income on custodial accounts, and certain payments on other account types.

In other words, it’s not just “this person has an account somewhere”. It’s “this person has this much, here, earning this”. The ATO then runs that data through its matching systems against what you’ve actually declared, which, if you haven’t lodged for five years, is a rather awkward nothing.

What does the ATO do with all this data?

In 2018, the honest answer was “they’re still sifting through it”. In 2026, the honest answer is “rather a lot”.

CRS data now feeds the ATO’s data-matching and risk-profiling systems alongside everything else they hold: AUSTRAC transfer records, immigration movements, property data, and reports from Australian banks and crypto exchanges. The practical result is the polite-but-pointed letter: “We have information suggesting you hold foreign accounts or received foreign income. Please review your affairs.” Thousands of expats have received one. It is not a letter that improves with ignoring.

And critically, the old “they can’t find me” defence is dead, because the CRS data includes your overseas address. The ATO doesn’t need to find you anymore. Your own bank told them where you live. For a closer look at how this plays out, see our related article: The ATO knows about your overseas bank accounts.

The next frontier: your crypto is joining the party

If you’ve been reading this thinking “good thing my money’s in crypto, not a bank”, I have news, and you won’t like it.

The OECD has built a sibling regime called the Crypto-Asset Reporting Framework (CARF), which does for crypto exchanges and wallet providers what the CRS does for banks. Dozens of jurisdictions are in the first wave, with crypto service providers in those countries already collecting customer transaction data from the start of 2026 for first exchanges between tax authorities in 2027. Australia has committed to implementing CARF along with an updated, modernised CRS, with its first crypto information exchanges expected from 2028, and a new domestic crypto reporting regime to sharpen the ATO’s view of Australian residents’ crypto along the way.

Translation: the window where offshore crypto sat in the ATO’s blind spot is closing on a published timetable. If your tax affairs have a crypto-shaped hole in them, the time to fix it is before the data starts flowing, not after.

What does this mean if your returns are overdue?

It means the maths has changed, permanently, in favour of coming forward.

Here’s the thing about the ATO: they are genuinely far gentler with people who put their hand up than with people they have to hunt down. Late lodgment penalties currently run at $330 for each 28 days a return is overdue, capped at $1,650 per return, plus interest charges on any tax owing. Stack up five or six outstanding returns and you can see how the bill grows. But the ATO has discretion to remit penalties, and that discretion gets exercised far more generously for voluntary disclosures than for taxpayers responding to a please-explain letter built on CRS data.

And here’s the bit that surprises people: bringing your returns up to date often isn’t the horror show you’ve built up in your head. Plenty of expats discover they’re owed refunds, or that their non-resident status means there was less to declare than they feared. The anxiety is usually worse than the outcome. Usually. The one scenario where it’s always worse is the one where the ATO moves first.

If you’re not sure whether you even need to lodge, start with our earlier article, Do I need to lodge a tax return while living overseas?, because even genuine non-residents generally need to lodge either a return or a non-lodgment advice. Silence satisfies nobody, least of all the ATO.

The bottom line

The era of the invisible expat is over. Your overseas bank reports you. Your overseas address travels with the data. Your crypto exchange is next on the roster. None of this is a reason to panic, but all of it is a reason to act, because every year that passes, the ATO’s picture of you gets sharper and your negotiating position gets weaker.

Tread your own path. Just lodge your returns while you’re walking it.

Put your hand up before the ATO taps your shoulder

Here’s the simple truth about overdue returns: the cost of fixing them voluntarily is almost always a fraction of the cost of being caught. Penalties get remitted for people who come forward. Refunds get found. Sleep gets recovered. We’ve brought hundreds of expats up to date, some with ten or more years of outstanding returns, and the most common reaction at the end isn’t pain. It’s “why didn’t I do this years ago?”

Our specialist expatriate tax team will review your situation, tell you exactly what needs lodging (and what doesn’t), and handle the whole catch-up process remotely, wherever in the world you are.

Book a FREE “General Enquiry” appointment with our expat tax specialists today and get the monkey off your back this month, not “someday”. Your future self (and your hip pocket) will thank you.

General information only. This article doesn’t consider your personal circumstances and isn’t tax or financial advice. Speak to our specialist expatriate tax team today, or with another registered tax agent, before acting.


References

  1. OECD, “Automatic Exchange of Information: Exchange relationships” (activated CRS exchange relationships between jurisdictions): oecd.org
  2. Australian Taxation Office, “OECD Crypto Asset Reporting Framework and domestic reporting” (Australia’s CARF implementation and first exchanges expected from 2028): ato.gov.au
  3. Australian Treasury, “Collective engagement to implement the Crypto-Asset Reporting Framework” (joint statement of jurisdictions committing to CARF): treasury.gov.au
  4. Australian Taxation Office, “Penalty units” (current penalty unit amounts used to calculate failure to lodge penalties): ato.gov.au
  5. Australian Taxation Office, “Automatic exchange of information: CRS and FATCA” (reporting and due diligence obligations of financial institutions): ato.gov.au
Shane Macfarlane CA
Managing Director · Chartered Accountant · Expatriate Tax Specialist

Shane's an Australian Chartered Accountant and Australian expat tax specialist who's also an expat himself (based in Asia). Shane's passionate about tax and legitimate tax minimisation, tax-planning and structuring, particularly as it relates to Australian expats who are often subject to high rates of tax back home in Australia.

Discussion

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K
kikkyie 2 years ago

There is nothing to worry about if one is not tax resident in Australia. There is nothing to report, and CRS data won’t be exchanged.

SM
Shane Macfarlane CA Expat Taxes Team 2 years ago

Hi kikkyie,

Thanks for your message. That’s not entirely true. Perhaps I’m being pedantic here, but if the foreign bank or financial institution BELIEVES you to be a tax resident, they have an obligation to report (regardless of whether you are or are not a tax resident – the foreign financial institution does not actually assess your residency status to determine your status).

Secondly, you say there’s nothing to worry about if one is not a tax resident of Australia – in fact, there’s nothing to worry about if you’re not trying to avoid or evade tax, and if you declare your income from all relevant sources correctly to the various country/countries that you reside in or have exposure to. Because the CRS data only confirms what you should have already correctly reported, so as long as you’re doing that, it’s actually nothing to worry about at all.

Finally, whilst we’re focusing on Australia in this conversation, it should be noted that the reverse also applies, if your Australian banks/financial institutions believe you to be a tax resident of say Belgium for example, as your details seem to imply, then under CRS, all your CRS data would be shared with the Belgian tax authority instead!

In fact, there’s a good chance that wherever you reside, it’s likely to be in a CRS country (as there are currently 115 countries actively exchanging CRS data at present with more countries being added ever year)!

Thanks once again for your comments kikkyie, it’s always good to hear your thoughts.

Cheers

Shane

T
Tim 7 years ago

Interesting article! – I’m surprised there aren’t any comments thus far, so I’ll lead with a request for clarification:

Are historical transactions on an account visible for dates prior to the date the CRS reporting period begins for that country?

Can you clarify a little how this works by way of an example?

eg say I had transactions through accounts held in my name in a country 2 years ago but the CRS reporting period for that country began this year. Would those old historical transactions be reported to the ATO, or is it only account balances as at the start of the CRS reporting period this year?

T
Tim 7 years ago

Following on from the earlier query, what about actual assessable income that has been taxed in a foreign country in years prior to the first CRS reporting period. Does that previous years tax assessment information get shared with the ATO after the CRS reporting commences?

SM
Shane Macfarlane CA Expat Taxes Team 7 years ago

It is only bank account information that gets shared Tim, although based on that bank account information, the ATO may use their powers under a tax information sharing agreement to request foreign tax return information from the foreign jurisdiction.

Thanks

Shane

SM
Shane Macfarlane CA Expat Taxes Team 7 years ago

Our understanding is that only transactions occurring within the period in question will be reported. Thus it is our understanding that historical transactions will not be reported prior to the start date of the period in question.

You should probably bear in mind however, that even through historical transactions may not be reported, if the ATO are scrutinising your current period transactions it is likely that they will seek information (including bank statements perhaps) from you for earlier periods so the fact that earlier transactions will not be reported is probably a moot point.

Thanks for your message Tim.

Regards

Shane

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