In this episode, we explore how certain jurisdictions remain outside the reach of CARF (Crypto-Asset Reporting Framework) — and why Svalbard and UK non-resident trusts continue to offer unique confidentiality advantages.

Key Insights:

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• Svalbard’s Unique Legal Shield
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• Under Article 8 of the 1925 Treaty of Svalbard, no signatory nation may receive tax benefits or preferential treatment related to Svalbard activities.
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• This means Svalbard cannot enter into tax treaties without breaching the principle of equal treatment among its 48 signatories — a list that includes Russia, China, and North Korea.
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• The result: Svalbard sits outside global tax-sharing agreements, including those underpinning CARF and CRS frameworks.
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• The UK’s Non-Resident Trust Advantage
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• The United Kingdom will not abolish its non-resident trust structure, a longstanding tool in international tax and estate planning.
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• A non-resident trust is governed by UK law but has trustees based outside the UK.
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• This allows for continued privacy and tax efficiency under UK rules — making such trusts valuable for asset protection and wealth transfer planning, even in an era of global transparency.
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Why It Matters:

While CARF expands global financial reporting, legal structures in Svalbard and the UK illustrate how specific jurisdictions remain beyond its direct reach — offering insights into the future of confidentiality and tax-neutral planning.

In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.

Key Takeaways:

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• RCASP Defined:
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• A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.
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• Entities Typically Considered RCASPs:
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1. 
   
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3. Centralized crypto exchanges (with or without custody services)
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7. Crypto brokers and dealers (acting as intermediaries or counterparties)
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10. 
    
11. Token issuers (creating and issuing crypto assets)
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15. Crypto-asset ATM operators
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19. Market makers
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23. Software providers only if they operate an exchange; app developers alone are excluded
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27. Decentralized exchanges (DEXs) where the operator exercises control or governance
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31. DAOs (Decentralized Autonomous Organizations) without legal recognition
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35. Businesses reselling crypto assets to customers
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37. 
    

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• Who Is NOT an RCASP:
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• Individuals or entities offering services infrequently or non-commercially
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• Platforms that only list prices or facilitate information without executing transactions
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• Developers or sellers of trading apps or software that are not used to execute transactions
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Why It Matters:

CARF holds RCASPs directly responsible for reporting transactions to authorities. Understanding whether you qualify as an RCASP is essential, because misclassification can lead to regulatory scrutiny and penalties.

In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.

Key Takeaways:

• 
  
• 
  
• RCASP Defined:
• 
  
• A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.
• 
  
• 
  
• 
  
• Entities Typically Considered RCASPs:
• 
  
• 
  

1. 
   
2. 
   
3. Centralized crypto exchanges (with or without custody services)
4. 
   
5. 
   
6. 
   
7. Crypto brokers and dealers (acting as intermediaries or counterparties)
8. 
   
9. 
   
10. 
    
11. Token issuers (creating and issuing crypto assets)
12. 
    
13. 
    
14. 
    
15. Crypto-asset ATM operators
16. 
    
17. 
    
18. 
    
19. Market makers
20. 
    
21. 
    
22. 
    
23. Software providers only if they operate an exchange; app developers alone are excluded
24. 
    
25. 
    
26. 
    
27. Decentralized exchanges (DEXs) where the operator exercises control or governance
28. 
    
29. 
    
30. 
    
31. DAOs (Decentralized Autonomous Organizations) without legal recognition
32. 
    
33. 
    
34. 
    
35. Businesses reselling crypto assets to customers
36. 
    
37. 
    

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• Who Is NOT an RCASP:
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• Individuals or entities offering services infrequently or non-commercially
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• Platforms that only list prices or facilitate information without executing transactions
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• Developers or sellers of trading apps or software that are not used to execute transactions
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Why It Matters:

CARF holds RCASPs directly responsible for reporting transactions to authorities. Understanding whether you qualify as an RCASP is essential, because misclassification can lead to regulatory scrutiny and penalties.

In this episode, we break down when crypto transactions become reportable under the Crypto-Asset Reporting Framework (CARF) — and why not every wallet movement or exchange triggers a filing.

Key Takeaways:

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• Spending Crypto Triggers Reporting:
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• Direct purchases of goods or services with crypto remain rare. Most users must convert crypto into fiat before spending — and that’s often where reporting begins.
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• Acquiring Crypto Assets:
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1. 
   
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3. With fiat currency: Report the total amount paid.
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7. By exchanging crypto: Report the fair market value (FMV) of what was acquired.
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• Disposing of Crypto Assets:
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1. 
   
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3. Selling for fiat: Report the gross amount received.
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7. Swapping crypto-to-crypto: Report the FMV of the asset disposed.
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• Retail Payment Transactions:
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• RCASPs must report retail crypto payments above $50,000, based on the FMV of goods or services purchased.
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• Transfers to Wallets:
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• Transfers to wallets outside the RCASP (like self-hosted wallets) must be reported if the wallet’s ownership isn’t known.
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• In such cases, the wallet address itself is omitted from the report but retained for regulators.
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• Transaction Categories:
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• Exchange Transactions: Crypto-to-fiat or crypto-to-crypto swaps (e.g., BTC to USD, ETH to stablecoin).
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• Transfers: Crypto moving between wallets or accounts under different control.
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• Reportable Retail Payments: Crypto used directly for large purchases.
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• Multiple Asset Reporting:
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• Each crypto type — or even NFT variation — may require its own report for the same user if traded or held separately.
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Why It Matters:

CARF’s detailed reporting structure ensures that both exchanges and users are fully visible to tax authorities once crypto moves — turning what was once “off-chain secrecy” into on-chain transparency.

In this episode, we unpack how the Crypto-Asset Reporting Framework (CARF) differs from its predecessors — FATCA and CRS — and why these differences matter for compliance and reporting transparency in the crypto era.

Key Takeaways:

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• Transaction-Based Reporting:
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• Unlike FATCA and CRS, which focus on income and asset values, CARF requires Reporting Crypto-Asset Service Providers (RCASPs) to disclose transactions made by reportable users.
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• Who Reports:
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• Under CARF, any entity or individual facilitating a relevant crypto transaction may be obligated to report — widening the net beyond traditional financial institutions.
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• When Reporting Happens:
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• Crypto assets are only reportable once a transaction occurs. For example, long-held Bitcoin that’s never moved doesn’t trigger reporting until it’s transacted — similar to “waiting for a submarine to surface.”
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• Closing the Shell Bank Loophole:
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• FATCA and CRS overlooked Professionally Managed Investment Entities (PMIEs) that weren’t required to report on themselves. CARF fixes this by “looking through” to the controlling persons behind such entities, potentially resulting in dual reporting by both the PMIE and the underlying Crypto-Asset Service Provider (CASP).
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Why It Matters:

CARF represents a new phase in global transparency — bringing crypto within the same rigorous framework that transformed traditional finance under FATCA and CRS.

The Crypto-Asset Reporting Framework (CARF) is designed to bring order, oversight, and accountability to the fast-moving world of digital assets. Its goals align closely with global efforts to prevent tax evasion, money laundering, and the misuse of crypto for illicit activity.

Key Objectives:

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• Increase Transparency — Shine a light on crypto asset holdings and transactions to help authorities track the flow of funds across borders.
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• Combat Tax Evasion & Financial Crime — Support efforts against tax evasion, money laundering, and terrorism financing.
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• Promote International Compliance — Ensure crypto markets adhere to shared global standards and align with established frameworks like the OECD and FATF.
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• Protect Financial System Integrity — Strengthen trust in the global financial ecosystem by bringing crypto into the regulatory mainstream.
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Why It Matters:

Crypto operates beyond traditional financial borders. The CARF, guided by the OECD and FATF, aims to close that gap—ensuring governments can cooperate, exchange data, and uphold consistent global standards.

The Crypto-Asset Reporting Framework (CARF) represents the next major evolution in global financial transparency. It builds upon a lineage that started with FATCA, evolved through the Common Reporting Standard (CRS), and now extends to the world of digital assets.

The Evolution:

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• FATCA (Foreign Account Tax Compliance Act) — Launched by the U.S., FATCA was the original model for cross-border reporting. It forced non-U.S. financial institutions to disclose information about U.S. account holders or face a 30% withholding penalty on U.S.-sourced payments.
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• CRS (Common Reporting Standard) — FATCA’s global successor, developed by the OECD, applied similar disclosure principles across participating jurisdictions.
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• CARF — Now, the OECD’s CARF expands this reporting framework into crypto assets, ensuring transparency and compliance in an area once thought to be beyond reach.
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Why It Matters:

CARF introduces structured, standardized rules for how crypto transactions are reported across borders. It aims to ensure tax authorities have visibility into digital asset holdings and transfers—bringing the crypto world into the same regulatory net as traditional finance.

In short:

FATCA started it, CRS globalized it, and CARF digitizes it—marking the next stage in the worldwide move toward financial transparency.

For many expats and entrepreneurs, maintaining or managing a foreign company while living in Portugal seems straightforward — but Portugal’s corporate tax rules can make things more complex than expected.

Key Point:

Unlike some countries that rely heavily on the “Place of Effective Management” (POEM) as a tie-breaker rule, Portugal uses “effective management” as a primary test for determining corporate tax residency.

Here’s what that means:

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• 🏢 Head Office: This refers to the company’s registered or legal office — where it’s incorporated.
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• 🧭 Effective Management: This is where the real decisions are made — strategic, commercial, and operational.
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If the Portuguese tax authorities determine that those key decisions are being made while you’re in Portugal, your company could be treated as Portuguese tax resident, even if it’s registered abroad.

The consequence:

That company’s worldwide income could become subject to Portuguese corporate tax.

In short:

Portugal treats the “effective management” rule as a central factor in deciding corporate tax residency — not just a secondary test. If you manage an offshore company while living in Portugal, professional tax advice is essential to avoid unexpected liabilities.