Is there any conflict or tension in Lebanon between privacy laws and the new CRS regulations?

In Lebanon, we still have bank secrecy laws, yet the issue is that CRS undermines that secrecy. As a result, there was a lot of debate about the adoption of CRS, but it was eventually implemented, alongside several laws around access to public information. If we hadn’t done this, the country would have been blacklisted back in September 2016. We don’t start with CRS reporting until January 2018, with our first report due in September 2018.

The CRS process starts with a request for information coming into the tax authority that will be assessed to see if there is any requirement for banking information. If there is, it will be sent to the central bank. The central bank has a joint committee with the Ministry of Finance, which will look at the details and assess whether the request has anything to do with individual bank accounts. If so, they will notify the bank account holder that there has been a request and then assess the next steps.

This creates real conflict between Lebanese privacy laws and CRS.

The above text is taken from the Tax Working Group Virtual Series – “Common Reporting Standards Imminent implications for client tax reporting” – read in full here.