CRS 2.0 Residence & Structuring Review
For internationally mobile individuals and families. Understand your position before enhanced reporting makes it visible.
Tax residence is not simply a matter of where a person lives. It is determined under the domestic law of every relevant jurisdiction, affected by treaty tie-break rules, and supported: or undermined: by the facts connecting the individual and family to each place.
From 1 January 2027, Singapore's amended CRS framework and Schema V3.0 filing requirements will materially increase the precision and consistency of information available across institutions and jurisdictions. Dual residents cannot assume that a treaty tie-break permits them to self-certify only one domestic-law residence. Treaty relief may still be relevant between tax authorities, but the underlying residence information may already have been reported.
The review provides a structured, fixed-fee entry point before broader wealth, succession or implementation decisions are taken.
Who the review is for
The review is designed for internationally mobile individuals and families where one or more of the following applies:
- The individual spends material time in Singapore and another jurisdiction.
- Family, home, business, economic or citizenship connections remain concentrated elsewhere.
- Existing bank, custodian, trust, fund or family-office self-certifications may not be consistent.
- A liquidity event, IPO, relocation or succession decision is approaching.
- PRC worldwide taxation, controlling-person reporting or CFC exposure may be relevant.
- Existing trusts, companies, funds, insurance wrappers or family-office structures were designed before the present residence position was established.
The initial methodology applies across jurisdictions, including connections with Mainland China, Hong Kong, Australia, the United Kingdom, the United States, and other key financial centres.
Stage 1: Residence and Risk Assessment
A structured questionnaire, followed by a written Residence & Risk Report.
Pricing
Fixed fee S$5,000
Turnaround
Typically 1-2 weeks
Client Time
Approx. 1 hour
What you receive:
- Structured CRS 2.0 Tax Residence Questionnaire.
- Review of residence ties across every material jurisdiction.
- Assessment of domestic-law tax residence in each relevant jurisdiction.
- Preliminary treaty tie-break analysis where dual residence arises.
- CRS 2.0 self-certification and reporting observations.
- Identification of potential worldwide taxation, controlling-person and structural exposure.
- Written Residence & Risk Report, typically 8-12 pages, with an executive summary and practical next steps.
Four Indicative Pathways
Two-by-two decision framework based on factual diagnostic outcomes.
Pathway A
Singapore residence established · other residence factors not established
Focus: Wealth-structure review, reporting alignment and estate planning.
Pathway B
Singapore residence established · other residence factors persist
Focus: Residence-risk review, evidence building, self-certification alignment and wealth-structure planning.
Pathway C
Dual resident · stronger Singapore treaty position
Focus: Documenting and maintaining the position, aligning structures and succession planning.
Pathway D
Dual resident · stronger non-Singapore treaty position
Focus: Evaluating whether to plan on that basis or deliberately reposition the family's centre over time, together with defensive structuring.
Why this review, from this firm
Michael Velten brings four decades across law firms, global financial institutions and Deloitte, in Australia, Hong Kong and Singapore, and is an Accredited Tax Adviser in both Singapore and Hong Kong. The review combines residence and treaty analysis with an understanding of CRS, FATCA and CARF reporting, family-office structures, succession planning and cross-border implementation.
The objective is not a residence conclusion in isolation. It is alignment between residence, reporting, wealth structures, succession objectives and the evidence required to withstand scrutiny.
Fixed Fee Review
S$5,000
Typically completed in 1-2 weeks