Common Reporting Standards (CRS) and the impact on trusts - case study

My I ask your opinion on a case I am confronted to.

NFE Trust holding underlying (FI) companies

  1.   A Trust with corporate trustees in Nevis (late adopter); has no bank account; only assets are the shares in three underlying companies (value @65 € / UC)
  2.   UCs are incorporated in the BVI (early adopters)

Each UC holds cash and investment portfolio (Banks are in late adopter countries).
UCs are owned at 100% by the trust.

  1.   The settlor of the trust is deceased

The beneficiaries of the trust are resident in early adopter countries but have never had a distribution.
Who will be reporting on whom?

Thank you in advance

Carmen Ciocan
Landmark Management