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Common Reporting Standard (CRS) and FATCA

Client Information Notice on CRS and FATCA

This notice provides general information to clients and prospective clients of ATHOS ASSET MANAGEMENT S.A. (the “Company”) regarding the collection, verification and, where required, reporting of tax-related information under the Common Reporting Standard (CRS), the EU framework on administrative cooperation in the field of taxation and the Foreign Account Tax Compliance Act (FATCA).

The notice is intended for information purposes only. It does not constitute tax, legal or investment advice. Clients should seek independent professional advice where they are uncertain about their tax residence, classification or reporting status.

1.Common Reporting Standards (CRS)

The Common Reporting Standard (CRS) was developed by the Organisation for Economic Co-operation and Development (OECD) as a global framework for the automatic exchange of financial account information between participating jurisdictions. Its purpose is to promote tax transparency and improve tax compliance internationally.

2.EU administrative cooperation framework

In the European Union, CRS reporting forms part of the broader framework of Directive 2011/16/EU on administrative cooperation in the field of taxation, as amended from time to time. The CRS framework was introduced through the amendment commonly referred to as DAC2. Subsequent amendments, including DAC8, further update and expand the administrative cooperation framework, in particular in relation to information reporting and exchange concerning crypto-assets and related transactions.

In Greece, the relevant rules have been implemented and amended through the applicable Greek legislation, including Law 4378/2016, Law 4428/2016, Law 4170/2013 as amended and in force, and Law 5301/2026, to the extent applicable.

3.Reporting obligations of the Company

Where required by law, the Company collects, verifies and reports relevant information to the competent Greek tax authority, the Independent Authority for Public Revenue (AADE).

The competent Greek tax authority may then exchange such information with the competent tax authorities of other participating jurisdictions in accordance with the applicable legal framework.

4.Information that may be requested from clients

In order to comply with the applicable obligations, the Company may request from existing and prospective clients, whether natural or legal persons, information and documentation including, as applicable:

  • Identification information, such as full name or legal name, address, date of birth, place of birth, country of incorporation or establishment and registration details.
  • Tax residence information and Tax Identification Number (TIN) or equivalent tax number issued by the relevant jurisdiction.
  • Information on the client’s status and classification for CRS and/or FATCA purposes.
  • For legal entities, information on controlling persons, beneficial owners or persons exercising control, where required by the applicable rules.
  • For clients who may be considered U.S. persons, completion of the relevant U.S. Internal Revenue Service forms, such as Form W-9, W-8BEN or W-8BEN-E, as applicable.
  • Supporting documents or self-certifications that may be required to verify the above information.

5.Client obligation to provide accurate and updated information

Clients are responsible for providing complete, accurate and up-to-date information and documentation requested by the Company for CRS, DAC and FATCA purposes. Clients must inform the Company without undue delay of any change in circumstances that affects, or may affect, their tax residence, tax identification details, FATCA status, CRS classification or other information previously provided to the Company.

Failure to provide the requested information or documentation may result in the Company being required to apply the procedures and reporting treatment prescribed by the applicable legislation and regulatory guidance.

6.FATCA

FATCA is a United States tax reporting regime designed to identify and report certain information in relation to U.S. taxpayers who hold financial accounts outside the United States. Greece and the United States have entered into an intergovernmental agreement for the implementation of FATCA, which has been ratified in Greece by Law 4493/2017.

As a result, Greek financial institutions may be required to identify clients who are considered “U.S. persons” for U.S. tax purposes and report relevant information through the competent Greek tax authorities, in accordance with the applicable rules.

7.Protection of personal data

The collection, processing, retention and reporting of personal data under CRS, the EU administrative cooperation framework and FATCA are carried out in order for the Company to comply with its legal obligations. Personal data are processed in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), Law 4624/2019 and the applicable data protection legislation, as amended and in force.

Personal data are retained securely and only for as long as necessary for the purposes for which they are collected, including compliance with legal, regulatory, tax, accounting and record-keeping obligations. Access to such data is restricted to authorised persons and service providers, where necessary and subject to appropriate safeguards.

Data subjects may exercise the rights provided under applicable data protection legislation, including rights of information, access, rectification, erasure, restriction of processing, objection and, where applicable, data portability. The exercise of these rights may be subject to limitations where processing is necessary for compliance with a legal obligation to which the Company is subject.

8.Further information