The main differences between FATCA and the CRS regarding which FIs must report are as follows:
Issue
CRS versus FATCA IGA
Reporting nexus
CRS uses residence of the Entity while IGA uses residence or where organised
Investment Entity
Definition differs between CRS and IGA
Non-reporting FIs
IGA includes Exempt Beneficial Owners and Deemed Compliant FFIs and other categories not in the CRS
There are some variations in terminology between FATCA and CRS. When the context requires, the following CRS terms should be read interchangeably with FATCA terms: