> Me thinks they are factoring in a high % of evasion under 100,000 euros per year gains.
Paultry individual investors have it the hardest to evade and optimize the taxes actually. Oftentimes they pay double dividend tax (WHT, only partial write off because of bilateral treaty, local dividend tax) while financial institutions were receiving... double refund of WHT (CumEx scandal).
Real brokers require TIN of an EU citizen and report the total capital gain over CRS to the country of your tax residence. If they don't do it they are not a broker and what you are buying with them are not shares.
The CRS is not valid for shares only for the cash amount held, (AKA the dry powder you have online to buy shares) which is not in scope for this law
And even then there are exceptions for examole you can do all your banking on Revolut which is a Money Service Business and MSB aren't part of the CRS because they are not banks. And you can also buy shares on there.
Also there is not a single person who got taken out by the CRS and it's been in place for 10 years now
This leaves as potential taxpayers only those who cannot afford or don't want to structure their holdings via offshore entities