Foreign Accounts and the German Tax Office 2026: These States Report – and These Do Not
On 30 September 2026, Germany's Federal Central Tax Office (BZSt) received account data from 118 states. For the tax office, a foreign account is therefore visible in most cases – in Switzerland as much as in Dubai, Turkey or Georgia. Some countries, however, still report nothing. This article shows the current position under the 2026 state exchange list, what data the tax office receives, what changes with CRD VI from January 2027 and how to open a foreign account legally and properly declared.
- ✛118 states transmitted account data to the BZSt by 30 September 2026, three more than in 2025: Rwanda, Senegal and Trinidad and Tobago.
- ✛Reported are name, address, tax ID, account number, year-end balance and income – no individual transactions.
- ✛States not reporting to Germany include the US (FATCA only), Russia, Serbia, Taiwan, Vietnam, the Philippines, Cambodia and the Dominican Republic.
- ✛Georgia, Armenia, Kazakhstan and the Gulf states do report – older lists are outdated here.
- ✛An unreported account is legal but does not change the obligation to declare income in your tax return.
118 states report in 2026 – three new ones added
The basis is the final 2026 state exchange list of the German Federal Ministry of Finance dated 8 June 2026. Under the Financial Account Information Exchange Act (FKAustG), Germany's implementation of the OECD CRS, it sets out which states Germany exchanges account data with.
The process: banks in partner states reported 2025 data to their tax authority. German banks delivered their data to the BZSt by 31 July 2026. The exchange took place by 30 September 2026. The BZSt now forwards the data to local tax offices, which match it against tax returns.
Compared with 2025 (115 states), three have been added. According to the BZSt CRS newsletter, Trinidad and Tobago is new on the list. With Rwanda and Senegal, a reciprocal exchange takes place for the first time from the 2025 reporting period.
The list includes all EU states, Switzerland, Liechtenstein, the UK, Singapore, Hong Kong, Turkey, Thailand, Panama, the classic offshore centres – and also Georgia, Armenia and Kazakhstan.
One-way street: offshore centres and Gulf states send but do not receive
For 25 of the 118 states, the ministry notes a special feature: they send data to Germany but receive none themselves. These include the Cayman Islands, the Bahamas, Bermuda, the British Virgin Islands and the United Arab Emirates, Qatar, Kuwait, Bahrain and Oman. Many of them levy no income tax and have no use for the data. Anyone who thinks money in Dubai is invisible is mistaken.
What the tax office sees – and what it does not
For each account, the bank reports once a year:
- ✛name, address, date of birth and tax identification number
- ✛account number and name of the bank
- ✛year-end balance or balance at closure
- ✛interest, dividends and other income
- ✛proceeds from the sale of securities
Individual transfers or transactions are not transmitted. Balance and income are enough for the tax office to spot gaps in a tax return, though. For corporate accounts, the bank also reports the controlling persons of passive entities – a shell company does not protect you.
Important: a country being on the list does not mean every account is reported. What matters is the tax residence you declare yourself when opening the account. False statements are not a loophole but an additional risk. Which documents banks require is shown in our KYC checklist for foreign accounts.
What the foreign bank does not do
A foreign bank generally does not deduct German withholding tax. You must therefore declare income from foreign accounts yourself in the investment income annex of your German return (Anlage KAP). This applies regardless of whether data is exchanged. Swiss taxpayers list foreign accounts in the securities register, Austrian taxpayers in their income tax return.
These states report nothing to Germany
Some countries are missing from the state exchange list. Accounts there are not automatically reported to the BZSt:
| State | Status | Background |
|---|---|---|
| USA | no CRS | exchange only via FATCA. Germany receives interest and dividend data but no balances. |
| Russia | exchange suspended | no data exchange with Germany since the war in Ukraine. |
| Serbia, North Macedonia | no CRS | EU candidate countries – the exchange will come with accession. |
| Taiwan | not with Germany | own CRS with few partners, Germany is not one of them. |
| Vietnam, Philippines | no CRS | no date for a first exchange. |
| Cambodia | no CRS | no date, heavily dollarised banking sector. |
| Dominican Republic, Guatemala | no CRS | no date for a first exchange. |
| Uzbekistan | no CRS | no date for a first exchange. |
| Cape Verde | no CRS yet | committed to first exchanges by 2027. |
Two special cases: Curaçao is on the German list but, according to the OECD, has temporarily suspended the exchange. Montenegro has committed but is not yet exchanging.
Important correction: Georgia and Armenia report
Many online guides still list Georgia and Armenia as non-reporting countries. That is outdated. Both are on the state exchange list – Georgia since the 2024 exchange, Armenia since 2025. The background and further countries are explained in our fact check on offshore accounts without CRS. Georgia nevertheless remains a good banking location – because of simple opening, solid banks and interest on foreign currency, not because of absent reporting.
No account is «invisible»
Even without automatic exchange, the tax office can learn about an account: through information requests under tax treaties, transfers to and from German accounts, foreign trade reporting or purchased data. An unreported account only reduces the likelihood of automatic detection. It does not make non-declaration legal.
11 January 2027: CRD VI restricts third-country banks
Alongside data exchange comes a second deadline: under Article 21c of the EU banking directive CRD VI (Directive 2024/1619), banks from non-EU states may, from 11 January 2027, generally only provide deposit and lending business to EU clients through an authorised branch. Germany implements this in its Banking Act.
What matters for clients: existing accounts do not have to be closed. And anyone who approaches a foreign bank on their own initiative falls under the reverse solicitation exemption. Banks will, however, become more cautious about active marketing in the EU and document more carefully who initiated the relationship. What this means in practice is shown in our CRD VI fact check.
Can you open an account digitally in these countries?
In short: rarely. Most banks in non-CRS countries require a visit in person, often a local address or residence permit as well. Purely digital opening for foreigners is the exception.
- ✛USA: the most likely digital option, usually via a US company. With an LLC, business accounts at US banks and fintechs can be opened remotely. More in our article on forming a Florida LLC.
- ✛Cambodia: for non-residents normally only with a residence permit. With a specialised partner, however, opening can be handled remotely.
- ✛Serbia, Philippines, Dominican Republic: usually require a personal visit.
- ✛Georgia (reports): possible remotely and a proven building block of international account structures – see opening a bank account in Georgia remotely.
How remote opening works and where its limits are is explained in our guide to opening a foreign account remotely.
Legitimate reasons for a foreign account
A foreign account is not a tool for tax evasion but a building block for security and flexibility. Typical reasons:
- ✛Diversification: spreading assets across several banking systems and jurisdictions
- ✛Protection against account freezes and capital controls at home
- ✛Privacy towards third parties: foreign accounts do not appear in Germany's domestic account retrieval procedure, so creditors and domestic bodies cannot see them at the push of a button
- ✛Currencies: accounts in USD, CHF or other currencies without detours
- ✛Business operations: handling payments in the markets where you operate
- ✛Relocation: an account in your future country of residence before you move
Which banking locations are suitable is compared in our article on bank accounts outside the EU. The most common mistakes are summarised in foreign accounts: mistakes and risks.
Obligations towards the tax office
Anyone with unlimited tax liability in Germany is taxed on worldwide income. For foreign accounts this means:
- 1Declare income: interest, dividends and capital gains belong in the Anlage KAP, even if the bank reports nothing.
- 2Report holdings: anyone holding at least 10% in a foreign company or acquiring shares for more than EUR 150,000 must notify the tax office under section 138(2) AO.
- 3Report payments: payments above EUR 12,500 to or from abroad must be reported to the Bundesbank under the Foreign Trade Regulation. Violations cost up to EUR 30,000.
- 4Observe CFC rules: passive income of a low-taxed foreign company is taxed in Germany.
Undeclared foreign income quickly counts as tax evasion. In particularly serious cases with a foreign element, prosecution is only time-barred after 15 years. Anyone who failed to declare income in the past can obtain immunity with a complete voluntary disclosure under section 371 AO – but only as long as the offence has not been discovered. With every data exchange this window gets smaller.
Crypto assets: reported from 2026 too
Crypto assets are not covered by the CRS. Since 1 January 2026, however, crypto service providers in the EU collect data under DAC8, which will be exchanged for the first time in 2027. Details are in our articles on crypto reporting and hardware wallets and crypto tax in Germany from 2027.
How SWICOR supports account opening
SWICOR helps individuals and companies open bank accounts abroad – with bank selection, preparation of KYC documents and communication with the bank. Our approach: an account that fits your situation and is correctly declared. No promise of anonymity, but a stable banking relationship that also holds up at the next compliance review.
| Location | CRS reporting to Germany | Typical use |
|---|---|---|
| Switzerland | yes | wealth management, stability, CHF |
| Georgia | yes | simple opening, interest on USD and EUR |
| Armenia | yes | regional diversification |
| USA | no (FATCA only) | business account for a US LLC, USD payments |
| Cambodia | no | USD account in Asia, diversification |
| Cape Verde | not yet, accession by 2027 | euro-linked account in West Africa |
| Dominican Republic | no | USD account in the Caribbean |
| Uzbekistan | no | account in Central Asia |
Whether a country reports or not does not change your declaration obligation. It does, however, help decide which location suits your goals. We assess this together with you and, where needed, work with tax advisers in your country of residence. All locations at a glance: bank account abroad.
Open a foreign account – with bank selection, KYC preparation and support until the account is approved.
Bank account abroad →Conclusion
The gap gets smaller every year: 115 states in 2025, 118 in 2026, and Cape Verde intends to follow by 2027. For the tax office, a foreign account is visible almost everywhere today – including Dubai, Georgia or the Cayman Islands. Non-reporting countries still exist, such as the US, Cambodia or Serbia. They are not a free pass, though.
A foreign account pays off for diversification, currencies, business operations and protection against account freezes – correctly declared. SWICOR . SWISS CORPORATE SOLUTIONS helps you choose the right location and open the account, transparently and at fixed prices.
Frequently asked questions
Will the tax office find out about my foreign account?
In most cases, yes. In 2026, 118 states automatically report account data to the BZSt, including Switzerland, the UAE, Turkey and Georgia. Balance and income are reported, not individual transactions.
Which countries do not report account data to Germany?
Among others, the US (FATCA only), Russia, Serbia, North Macedonia, Taiwan, Vietnam, the Philippines, Cambodia, the Dominican Republic, Guatemala and Uzbekistan.
Is an account in a non-CRS country legal?
Yes. You must still declare the income in your tax return. The absence of data exchange does not change your tax liability.
Does Dubai report account data to the German tax office?
Yes. The UAE is on the 2026 state exchange list. It sends data to Germany but receives none itself.
Do I have to register my foreign account with the tax office?
You do not have to register the account itself, but you must declare the income. Holdings of 10% or more in foreign companies and payments above EUR 12,500 have their own reporting obligations.
What changes from 11 January 2027?
Banks from non-EU states may then generally only offer deposit business to EU clients through a branch. Existing accounts and contact on the client's own initiative remain possible.
Open a foreign account legally and securely?
We find the right banking location for your situation, prepare the documents and accompany the opening – in Switzerland, Georgia, the US, Cambodia and other countries.
This article is a general analysis and does not replace individual tax or legal advice. Regulations change; the information reflects the status at the date of publication.