Updated: June 2026

Case study · Malta · Tax

How Swiss Accounts Were Removed from CRS Auto-Exchangewith CIS Countries Through Genuine GRP Malta Status

Swiss banks have long ceased to be a haven from information exchange - they are among the most disciplined CRS participants. Semyon Mikhailovich's substantial accounts at UBS and Julius Baer were reported annually to his tax residency country in the CIS region, and the Caribbean residence permit he had previously purchased was no longer recognized by Swiss compliance as genuine tax registration. We explain how genuine Malta resident status redirected reporting and closed the risks.

Dmitry NagyDmitry NagyInternational Tax Consultant, BRIDGESReading time10 min readVerificationReviewed by an expert

This case is based on a real matter. The name and certain identifying details have been changed to protect confidentiality.

BRIDGES client story - How Swiss Accounts Were Removed from CRS Auto-Exchange with CIS Countries Through Genuine GRP Malta Status
Contents

Case at a glance

Situation, solution and outcome in seven lines

Client
Semyon Mikhailovich, 61 years old, high-net-worth investor
Origin
Tax resident of CIS country
Program
Malta, Global Residence Programme
Assets
Substantial accounts at UBS and Julius Baer
Problem
CRS auto-exchange with CIS countries; Caribbean residence permit not accepted by banks
Solution
Genuine Malta resident status; CRS reporting redirection
Result
Reporting redirected to Malta; status resistant to compliance scrutiny

Client story

Client's Story

Where they started

Semyon Mikhailovich spent decades building capital and storing it where he was accustomed to trusting - in Swiss UBS and Julius Baer. For a long time, this meant security and confidentiality. However, with the advent of automatic financial information exchange, the silence ended: banks are obligated to report account data annually to the account holder's country of tax residence.

Why the standard route did not work

Several years ago, like many others, he was sold a Caribbean residence permit under the promise that it would resolve his residency issue. On paper, he had a passport or residence permit, but Swiss compliance quickly tightened its approach: banks ceased accepting formal Caribbean status without actual presence as genuine tax registration. Reporting continued to be sent to the CIS country.

What BRIDGES had to solve

For Semyon Mikhailovich, these were not abstract risks. Annual transmission of account balance data to a jurisdiction with unpredictably changing rules meant constant threat - from tax reassessments to inquiries he had no desire to answer at his age and with his level of capital.

Why a standard answer would not do

He came to BRIDGES with a specific task: to obtain not mere paperwork, but genuine tax resident status recognized by Swiss banks in a respected European jurisdiction, so that CRS reporting would go to a jurisdiction with clear and favorable tax treatment for him.

For years I was told that a Swiss bank account is secure and confidential. It turned out the confidentiality works best where you have genuine status, not purchased paperwork. The bank simply did not accept the Caribbean residence permit. BRIDGES created genuine residency, and the concerns disappeared.

Semen, 61 · Semyon Mikhailovich, InvestorThe name and certain identifying details have been changed to protect confidentiality.

What Was at Risk

What Was at Risk

The main mistake is believing that any second document resolves the CRS issue. Swiss banks long ago learned to distinguish genuine tax residence from formal status: without presence and substance, Caribbean status does not exist for them, and reporting goes to where you actually reside.

Annual transmission of UBS and Julius Baer account data to CIS jurisdiction;

  1. 01Refusal of Swiss compliance to recognize Caribbean residence permit as tax registration;
  2. 02Threat of tax reassessments and claims in a country with unpredictably changing rules;
  3. 03Risk of restrictions by the banks themselves due to unclear tax status of the client;
  4. 04Absence of a document that Switzerland trusts - a clean certificate of residency.

The logic of the solution

How the matter progressed: from checks to result

The chart is built from the facts of this matter and shows the logic of the work without decorative or unverified data.

  1. 01
    Stage 1

    We assessed the account structure at UBS and Julius Baer and determined which status Swiss compliance would accept as genuine.

  2. 02
    Stage 2

    We established GRP status with genuine substance: qualified rental housing, insurance, physical presence, fit and proper assessment.

  3. 03
    Stage 3

    We obtained a Maltese Tax Residence Certificate - a document trusted by Swiss banks.

  4. 04
    Stage 4

    We submitted tax residency updates to UBS and Julius Baer so that CRS reporting would be directed to Malta.

  5. 05
    Stage 5

    We established non-domiciled status and segregated income streams so that foreign income would not be taxed in Malta until brought to the island.

Takeaway. Semyon Mikhailovich's foreign income, until brought to the island, is not taxed in Malta under the non-dom principle. The status is backed by real substance, making it resilient to both bank compliance and tax review - unlike the previous Caribbean residence permit.

How we solved the issue

How we solved the issue

The work was split into verifiable stages so that every conclusion rested on documents.

  1. 01

    Stage 1

    We assessed the account structure at UBS and Julius Baer and determined which status Swiss compliance would accept as genuine.

  2. 02

    Stage 2

    We established GRP status with genuine substance: qualified rental housing, insurance, physical presence, fit and proper assessment.

  3. 03

    Stage 3

    We obtained a Maltese Tax Residence Certificate - a document trusted by Swiss banks.

  4. 04

    Stage 4

    We submitted tax residency updates to UBS and Julius Baer so that CRS reporting would be directed to Malta.

  5. 05

    Stage 5

    We established non-domiciled status and segregated income streams so that foreign income would not be taxed in Malta until brought to the island.

  6. 06

    Stage 6

    We ensured compliance with the 183-day rule and connection to the island so that the status would withstand both bank and tax scrutiny.

Expert comment

A Caribbean passport is an excellent tool for mobility, but it was not designed to solve the CRS issue, and Swiss banks understood this long ago. They do not check for the presence of a document, but verify the authenticity of tax residency: where you live, whether you have housing, physical presence. Therefore, the only honest answer to automatic exchange is not to hide accounts, but to establish genuine residency in a jurisdiction with a reasonable regime. Malta is ideal for this, and UBS and Julius Baer accept its status without question.

Dmitry Nagy, International Tax Consultant, BRIDGESDmitry NagyInternational Tax Consultant, BRIDGES

Outcome

What the client received

Indicator
Before · After
CRS reporting destination (UBS, Julius Baer)
CIS country · Malta
Bank recognition of status
Caribbean residence permit rejected · Malta TRC accepted
Tax on unremitted foreign income
Unpredictable · 0% (non-dom)
Resilience to compliance
Low · High (genuine substance)
Resilience to compliance
Low · High (genuine substance)

After establishing genuine status, Swiss banks accepted the Maltese Tax Residence Certificate, and CRS reporting for UBS and Julius Baer accounts was directed to Malta. The threat of annual data transmission to a CIS jurisdiction was eliminated, along with the constant anxiety over potential claims.

Practical takeaway

What matters in a similar situation

  • Semyon Mikhailovich's foreign income, until brought to the island, is not taxed in Malta under the non-dom principle. The status is backed by real substance, making it resilient to both bank compliance and tax review - unlike the previous Caribbean residence permit.
  • This case demonstrates a simple principle: half-measures do not work against CRS. Swiss banks will reject a purchased formal status but will accept genuine residency in a reputable jurisdiction. The difference lies in substance, and that is precisely what we build.

FAQ

Questions people ask in a similar situation

01Why did the Swiss bank not accept the Caribbean residence permit?

Swiss compliance verifies the reality of tax residency - presence and substance. A formal Caribbean status without actual residence is not recognized by banks as tax residency.

02How does Malta redirect CRS?

With genuine Malta resident status and a TRC certificate, the bank directs CRS reporting to your country of actual tax residency - Malta.

03Is this account concealment?

No. Accounts remain transparent, information exchange occurs - but is directed to a jurisdiction with a favorable tax regime where you genuinely reside under the program's rules.

04Is foreign income taxed in Malta?

Under non-dom status, foreign income is not taxed until it is brought into the island. Income brought in is taxed at a preferential rate within the GRP framework.

05What makes the status resistant to scrutiny?

Genuine substance: qualified housing, physical presence, compliance with the 183-day rule. We establish this before obtaining the certificate.

06Swiss accounts are reported via CRS to CIS countries, and Caribbean residency is not accepted by banks?

We will establish genuine Malta resident status with substance trusted by UBS and Julius Baer, and redirect CRS reporting to a jurisdiction with favorable tax treatment.

About the author

Dmitry Nagy

Author: Dmitry Nagy

International Tax Consultant, BRIDGES

I lead the international tax practice at BRIDGES and work at the intersection of tax residence, cross-border reporting and banking compliance. I assess how citizenship, residence, relocation or a new ownership structure may affect the client's tax obligations, banking profile and capital.

My work covers tax residence, CRS and FATCA requirements, source of funds and the questions a bank may raise. These elements should be considered together, because inconsistencies between documents, declarations and the underlying circumstances can create risks after a status has been obtained or an account has been opened.

During the consultation, you will receive an assessment of the tax and banking implications of the proposed decision. Where further work is required, I determine the financial documentation and personally oversee the tax and compliance aspects of the BRIDGES project.

Prepared on the basis of BRIDGES practice and reviewed by a subject-matter expert.

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Dmitry NagyInternational Tax Consultant, BRIDGES
Dmitry Nagy, International Tax Consultant, BRIDGES

Names and certain details have been changed to protect client confidentiality. The result described reflects one specific situation and is neither a public offer nor a guarantee of a similar outcome. Programme terms are stated as of 2026 and may change - please confirm current parameters with a BRIDGES consultant.