On 29 October 2014, all OECD member states and G20 countries endorsed the new OECD/G20 standard on automatic exchange of tax information at the Global Forum on Transparency and Exchange of Information for Tax Purposes in Berlin.
During a global signing session of a Multilateral Competent Authority Agreement that will activate automatic exchange of information, 51 jurisdictions put their commitments into action. The Agreement is based on the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.
The new Standard for Automatic Exchange of Financial Account Information in Tax Matters provides for an automatic exchange of all financial information on an annual basis. Most jurisdictions have committed to implementing this Standard on a reciprocal basis with all interested jurisdictions.
The information exchanged will include:
– name and address;
– taxpayer's identification number;
– date and place of birth;
– account number; and
– balance, as well as interest, dividends or gains derived from the alienation of these financial assets.
The agreement also includes a requirement that beneficial ownership of all legal entities will be made available to tax authorities and exchanged with treaty partners. It contains clauses to protect taxpayer confidentiality and ensure that the information is only used for the purposes for which it was supplied.
OECD Secretary-General Angel Gurría announced that of the 123 Global Forum members, nearly 90 have committed to implement the common reporting standard (CRS) for automatic, reciprocal exchange of tax information. A status report on committed and not committed jurisdictions will be presented at the annual G20 summit in Brisbane, on 15-16 November.
Early adopters (see below) who signed the agreement have pledged to work towards launching their first information exchanges by September 2017. Others are expected to follow in 2018. This list includes Switzerland, Hong Kong, Singapore, Macao, Monaco, Antigua and Barbuda, the Bahamas, as well as Australia, New Zealand and Canada.
Five jurisdictions have not yet committed to an implementation date: Panama; Bahrain; Cook Islands; Nauru; and Vanuatu.
The USA is an exceptional case in that it does not appear in any of the lists since it is unilaterally imposing automatic information exchange from 2015 under the Foreign Account Tax Compliance Act.