Financial advisors guiding digital nomads relocating to Spain must understand how international tax reporting regimes work. Spain taxes its residents on worldwide income, so newcomers (including holders of Spain’s new Digital Nomad Visa) should be aware that their foreign bank accounts and investments are not hidden from the Spanish Tax Agency. Two key frameworks enable cross-border sharing of financial account information: the U.S. Foreign Account Tax Compliance Act (FATCA) and the OECD’s Common Reporting Standard (CRS). Below we explain each, compare their scope, and detail how CRS is implemented in Europe—especially in Spain—to automatically inform Spanish authorities about assets held abroad.
Understanding FATCA and CRS
Foreign Account Tax Compliance Act (FATCA): FATCA is a U.S. law enacted in 2010 to combat tax evasion by U.S. persons holding assets overseas. It requires foreign financial institutions (FFIs) worldwide to identify and report accounts held by U.S. taxpayers to the U.S. Internal Revenue Service (IRS)investopedia.com. In practice, banks, investment platforms, and other FFIs must either register with the IRS or comply via Intergovernmental Agreements. FATCA also places an onus on U.S. citizens and residents to annually self-report their foreign financial assets (via IRS Form 8938) above certain thresholdsinvestopedia.com. Non-compliance is enforced by a hefty 30% withholding on U.S.-source payments to non-cooperative institutions, pressuring FFIs and jurisdictions to participate. FATCA’s reach is essentially one-directional (funneling information to the U.S.), though some partner countries have limited reciprocity from the U.S. on certain income data.
Common Reporting Standard (CRS): The CRS is a global standard for the automatic exchange of financial account information between tax authorities, developed by the OECD in 2014en.wikipedia.org. Its primary goal is to combat offshore tax evasion by enabling countries to share data on their taxpayers’ foreign holdings reciprocally on a multilateral basis – an approach inspired by FATCA’s successen.wikipedia.org. Under CRS, more than 100 jurisdictions (over 120 as of 2025) have committed to automatically exchange information on financial accounts held by each other’s residentsen.wikipedia.org. Participating financial institutions collect customers’ tax residency details and report account information to their local tax authority, which in turn forwards it to the account holders’ country of tax residence. Unlike FATCA, CRS is not tied to one country’s taxpayers; it’s a global network where, for example, Spain can receive data about a Spanish resident’s accounts in France or Singapore, and vice versa. The first CRS exchanges began in 2017en.wikipedia.org, and the legal framework is based on the OECD’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters and a Multilateral Competent Authority Agreement (MCAA) to implement the standarden.wikipedia.org.
In summary: Both FATCA and CRS create transparency by sharing financial account data across borders, but FATCA is a unilateral U.S. system focusing on U.S. taxpayers, while CRS is a multilateral, global system. The table below highlights key differences and similarities between the two:
Aspect | FATCA (U.S.) | CRS (Global OECD Standard) |
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Origin & Initiator | United States (U.S. law, 2010)sede.agenciatributaria.gob.es. | OECD initiative (2014), built on a multilateral conventionen.wikipedia.org. |
Primary Purpose | Combat tax evasion by U.S. persons with foreign accounts. | Combat global tax evasion through reciprocal information exchange. |
Participating Countries | One country (USA) + >110 partner countries via bilateral IGAs (information mainly flows to the US). | 120+ jurisdictions worldwide (all EU countries and major financial centers) exchanging with each otheren.wikipedia.orgsede.agenciatributaria.gob.es. |
Legal Framework | U.S. Internal Revenue Code §§1471–1474; enforced via IGAs or direct FFI agreements. | OECD’s Common Reporting Standard and MCAA; in EU implemented via Directive 2014/107/EU (DAC2)sede.agenciatributaria.gob.es. |
Scope of Reporting | Foreign institutions report U.S. account holders’ data to IRS; U.S. taxpayers report their foreign assets to IRS. | Institutions in each country report non-residents’ accounts to their local authority, which shares with the respective countries of residence. All participating jurisdictions both send and receive data (reciprocal by default). |
Data Exchanged | Identifying info on U.S. account holders; account numbers, balances, interest, dividends, and other incomesede.agenciatributaria.gob.es. (U.S. shares limited info back to partners under IGAs.) | Account holder identity and tax ID, account details, account balance or value, interest, dividends, other investment income, and sale proceeds creditedsede.agenciatributaria.gob.essede.agenciatributaria.gob.es. (Broad range of financial accounts: bank deposits, custodial accounts, certain insurance, trusts, etc.) |
Thresholds & Coverage | FFIs may omit some small accounts (<$50k for individuals in some cases); U.S. individuals report if total foreign assets exceed $50k (higher if abroad or married). | No universal de minimis – CRS includes both high-value and lower-value accounts, though preexisting individual accounts under $1M had slightly lighter due diligence. In practice most accounts held by non-residents are reported. |
Enforcement Mechanism | 30% withholding penalty on non-compliant foreign institutions; significant IRS penalties for individuals who fail to file. | Jurisdictions subject to peer reviews by the Global Forum; domestic laws impose penalties on institutions for non-reporting. Relies on international cooperation and pressure (no single financial sanction like FATCA’s). |
Reciprocity | Mostly one-way (data goes to U.S.). IGAs (Model 1) allow U.S. to share certain info (e.g. interest paid to partner country’s residents), but U.S. does not report account balances of foreign nationals. | Fully two-way among participating states (e.g. Spain ↔ France exchange). Some jurisdictions can choose to send only (non-reciprocal), but major financial centers participate reciprocallysede.agenciatributaria.gob.es. |
Impact on Individuals | U.S. taxpayers must file annual FATCA forms (Form 8938) in addition to FBAR. Foreign banks often require U.S. clients to provide IRS Form W-9 and consent to report. | Taxpayers in CRS countries generally have no separate CRS filing—information is collected by banks and sent automatically. However, they are still required to declare foreign income/assets per their domestic law (e.g., Spain’s Modelo 720 asset report). |
Note: In Spain, FATCA and CRS intersect – Spain signed a FATCA agreement with the U.S., enabling data exchange about accounts of U.S. persons, and also implemented CRS for global exchanges. In fact, Spain’s first automatic account exchange was with the U.S. in 2015 under FATCAsede.agenciatributaria.gob.es, shortly before CRS went live.
CRS Implementation in Europe and Spain
Europe’s Adoption (DAC2): European Union countries have integrated the CRS standard into EU law via the Directive 2014/107/EU (known as DAC2), which amended the administrative cooperation directive to include automatic exchange of financial account informationsede.agenciatributaria.gob.es. This means all EU member states (Spain included) are obligated to collect data from their financial institutions and exchange information annually with each other, aligning with CRS. European tax authorities also exchange other types of income data (such as salaries, pensions, and property income) under earlier directives, but CRS (DAC2) specifically covers financial accounts like bank and investment accounts.
Spain’s Participation: Spain was an early adopter and pioneer in implementing CRSsede.agenciatributaria.gob.es. Spain signed the multilateral CRS agreement in October 2014sede.agenciatributaria.gob.es and updated its domestic laws to require Spanish financial institutions to due-diligence and report non-residents’ accounts. In turn, the Spanish Tax Agency (Agencia Tributaria or AEAT) started receiving CRS data from abroad in 2017. By the first exchange in late 2017, Spain exchanged information with 49 jurisdictions; by 2018, the network grew to 100, and as of the 2021 exchange, Spain was connected with 108 countries and jurisdictions sharing financial account datasede.agenciatributaria.gob.es. This includes major international financial centers and former tax havens – a remarkable change from years past when bank secrecy would have prevented such transparencysede.agenciatributaria.gob.es. In effect, most countries where a Spanish tax resident might hold an account are likely participating in CRS (notable exception: the United States, which uses FATCA instead).
How the Spanish Tax Agency Receives Foreign Account Data: Under CRS, the process is automatic and annual. Financial institutions worldwide determine the tax residency of their customers (typically via self-certification forms) and report relevant account details for customers who are foreign residents. Each jurisdiction’s tax authority then forwards the information to the tax authorities where those customers reside. For example, if a client from Spain holds a bank account in France, the French bank will report that account to French authorities, who will automatically send the data to Spain’s Agencia Tributaria. Spain does the same for accounts in Spanish banks held by residents of other countries. The types of financial information exchanged are extensive, including:
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Account holder details: name, address, country of tax residence, tax identification number (NIF), etc.
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Account details: the foreign account number or identifier and the name of the financial institution.
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Account balance or value: typically the year-end balance of the account (or cash value for certain insurance/contracts)sede.agenciatributaria.gob.es.
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Investment income: interest earned, dividends received, and other income generated by the assets in the accountsede.agenciatributaria.gob.es.
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Sales proceeds or redemptions: for custodial accounts, gross proceeds from the sale of financial assets are reportable (so that capital gains can be inferred).
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Other financial income: such as unit trusts income, cash value insurance payouts, annuities, etc., where applicable under CRS definitions.
According to Spain’s Tax Agency, the information they receive covers “account ownership, balances, dividends, interest, redemptions, and other capital income” earned in any of the 107 foreign countries (as of the latest count) where Spanish residents hold accountssede.agenciatributaria.gob.es. This data arrives automatically each year and is incorporated into the Spanish tax authority’s databases for cross-checking tax returns. In sum, if a Spanish tax resident has a bank account, brokerage account, or similar financial asset abroad, Spanish authorities will likely know about it via CRS.
CRS & Digital Nomads in Spain: For clients relocating under Spain’s Digital Nomad Visa, this means that once they trigger Spanish tax residency (e.g. by spending >183 days in Spain or meeting other criteria), their worldwide financial accounts become transparent to Spain. All EU countries, the UK, Canada, Australia, China, Switzerland, and many others participate in CRS, so accounts in any of these jurisdictions will be reported to Spainsede.agenciatributaria.gob.essede.agenciatributaria.gob.es. Notably, even traditional offshore banking centers (Luxembourg, Switzerland, Cayman Islands, etc.) now routinely exchange account data with Spain, marking the end of bank secrecy for tax purposessede.agenciatributaria.gob.es. The United States, again, is a special case – it does not partake in CRS, but Spain receives some information from the U.S. through the bilateral FATCA deal (mostly interest income on Spanish residents’ U.S. accounts)sede.agenciatributaria.gob.es. U.S. citizens living in Spain should be aware that Spanish banks will report their accounts to the U.S. (FATCA), and they must file U.S. tax forms, while U.S. banks may report certain info to Spain (FATCA reciprocity) though not as comprehensively as CRS would. In any case, non-U.S. digital nomads in Spain can assume their foreign accounts are reported via CRS, and U.S. citizen nomads have dual reporting through FATCA.
Financial Institutions’ Role and Compliance Example
From banks to fintech companies, financial institutions play a pivotal role in these regimes by collecting customer information and transmitting reports. Even newer fintech platforms like Wise (formerly TransferWise) must comply with FATCA/CRS in relevant product offerings. Wise notes that certain entities in its group fall under FATCA and CRS obligations – for example, Wise’s U.K. brokerage subsidiary (Wise Assets) is considered a financial institution and will report “reportable” customers to tax authorities under the Automatic Exchange of Information (AEOI) ruleswise.com. Wise has been working with industry groups and the OECD to implement processes that identify customers’ tax residencies and report their financial data to the appropriate authorities whenever requiredwise.com. This means if a Spanish tax resident uses a service like Wise Assets or earns investment income through Wise, that information could be reported to Spain’s tax agency just as a bank would report it.
It’s also important to distinguish information reporting from tax withholding. Some countries levy withholding taxes on investment income at source, which is a separate obligation from CRS/FATCA reporting. For instance, Wise Europe (based in Belgium) withholds a 30% tax on interest earnings (branded as “balance cashback”) for customers in the EEAwise.com. Wise remits that tax to Belgian authorities, but the customer may need to report the interest on their Spanish tax return and possibly claim a foreign tax credit or refundwise.com. In such cases, CRS ensures Spanish authorities are aware of the income: the Belgian tax authority will still exchange the account and interest information with Spain. The takeaway for advisors is that clients must remain compliant in each jurisdiction – paying any owed taxes locally and reporting income globally – because tax offices will have the data to verify it.
Conclusion
Relocating to Spain as a digital nomad offers many perks, but financial secrecy is not one of them. Through FATCA and especially the Common Reporting Standard, Spain’s Hacienda can access details of bank accounts and investments held abroad by Spanish tax residents automatically. Over a hundred countries now participate in this automatic exchange, making the world of finance far more transparent. For financial professionals advising internationally-mobile clients, it’s crucial to ensure they understand these reporting regimes. Clients should be counseled to declare all overseas assets and income on their Spanish tax filings (and continue complying with any home-country requirements like FATCA for U.S. persons). The era of easily “hiding” money offshore is over – but with proper planning (e.g. using foreign tax credits, timing asset sales, or utilizing Spain’s tax treaties), digital nomads can legally optimize their taxes while staying fully compliant. By staying informed on FATCA and CRS, advisors can help their clients avoid pitfalls and embrace transparency as a part of sound financial planning for their new life in Spain.
From January 2026, institutions like Revolut, Wise, and traditional banks must start sending detailed and regular reports to the Spanish Tax Agency (AEAT), covering: Monthly data on bank accounts: balances, transactions, and account holders.
Sources: OECD & Agencia Tributaria (Spain) on CRS; Wise.com on tax reporting obligations; U.S. IRS guidelines on FATCA