CRS classification: the 2017 ASP guide has been withdrawn
Administrative service providers and corporate trustees should reassess reliance on the old guide.
On 17 September 2026, the Tax Department withdrew its June 2017 guide on whether administrative service providers are financial institutions under FATCA and CRS, with effect from that announcement.
For CRS classification, the Department points to paragraph 10ter of the commentary on Section VIII in the OECD’s consolidated CRS text (2025): relevant remuneration counts towards the gross-income test even when another entity receives it. A corporate trustee should therefore not assume that receiving no direct fee settles its classification.
Practical next step: review classifications, fee arrangements and reporting procedures against the applicable CRS framework. The withdrawal of guidance does not itself determine every entity’s status.
Official sources
- Cyprus Tax Department — withdrawal of ASP guide, 17 September 2026
- OECD, Consolidated CRS (2025), Section VIII commentary, paragraph 10ter, page 83
General information only; not legal advice. Please contact us about your circumstances.