Question 1

Where do I find official guidance on CARF/DAC8 implementation?

Accepted Answer

The primary source is the OECD's 2022 CARF document: full rules, Commentary, and XML Schema User Guide — all downloadable from the OECD CARF page. The OECD also publishes periodic implementation FAQs covering edge cases (nexus thresholds, tokenized assets, SEMP scope changes). For EU implementation, DAC8 (Council Directive (EU) 2023/2226) is the binding text; Commission Implementing Regulation (EU) 2024/2680 specifies the reporting XML format. At national level, each member state's tax authority publishes its own transposition guidance and filing portal instructions.

Question 2

Does having customers in a jurisdiction require CARF registration there?

Accepted Answer

No — per OECD CARF FAQ guidance, customer presence alone does not meet the 'regular place of business' standard that triggers nexus. A provider that is not tax resident, not incorporated, has no employees and no servers in a jurisdiction will not have CARF registration obligations there merely because it has customers with addresses in that jurisdiction. Nexus requires a more substantial operational presence.

Question 3

Are tokenized financial assets reportable under CARF or CRS?

Accepted Answer

It depends on transferability. Tokenized financial assets that can only be transferred within Depository or Custodial Institutions (intermediated) may be excluded from CARF and reported under CRS only. If the token can be transferred to a customer's self-hosted wallet (disintermediated), it remains in scope of both CARF and CRS. Clarified in OECD CARF/CRS implementation FAQs.

Question 4

What happens if a stablecoin becomes a SEMP partway through the year?

Accepted Answer

Per OECD FAQ guidance: transactions are CARF reportable up to the date the stablecoin becomes a SEMP, and the account becomes CRS reportable from that date forward. Local jurisdictions may allow retroactive SEMP treatment for the full calendar year — left to local law. Switzerland note: CARF implementation postponed to 1 January 2027, but the CRS SEMP amendment applies from 1 January 2026.