This article was written by Emma Marshall — Community Manager
We believe this article is accurate at the time of writing, but regulations evolve. We'd welcome you to contact us for a quick, up-to-date confirmation—we're always glad to help.
For internationally mobile individuals structuring their financial and residency footprint, the intersection of CRS participation and investment migration has become a meaningful planning consideration. Seven jurisdictions currently sit outside the OECD's automatic data exchange network, each offering a credible residency or citizenship route.
What this article covers:
- Which countries currently sit outside the CRS framework and why
- The investment migration routes available in each jurisdiction
- Paraguay's new Investor Pass and what makes it notable in 2026
- How Marlow Bray approaches combined residency and wealth structuring
The CRS Landscape in 2026
The OECD's Common Reporting Standard now covers over 100 jurisdictions that automatically exchange financial account data.
The seven countries analysed here, including the United States, Cambodia, Paraguay, and Serbia, operate outside that network for various structural or political reasons.
For clients with a genuine need for international diversification, this creates planning optionality that extends well beyond straightforward tax efficiency.
Paraguay's Investor Pass, launched in April 2026, is a notable addition: it offers permanent residency by investment from US$150,000, a territorial tax regime, and a three-year path to citizenship.
What This Means for Wealth Structuring
For Marlow Bray clients, the question is rarely about secrecy and almost always about genuine diversification and the legal clarity that accompanies a properly established second domicile.
A second residency in a CRS non-participating jurisdiction can sit coherently within a broader international structure, provided it reflects real ties and is supported by qualified legal and tax counsel.
Paraguay, in particular, represents a credible and underrepresented option for clients seeking a low-threshold route alongside more established citizenship by investment programmes in Europe and the Caribbean.
When structured carefully, these routes complement rather than conflict with a client's wider financial planning.
If you are reviewing your international residency position or considering how investment migration fits within your overall strategy, Marlow Bray's advisory team is well placed to help you assess the right options for your circumstances.
