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.
Country Date of first exchange of information
1. Albania September 2018
2. Anguilla September 2017
3. Argentina September 2017
4. Aruba September 2018
5. Austria September 2018
6. Belgium September 2017
7. Bermuda September 2017
8. British Virgin Islands September 2017
9. Cayman Islands September 2017
10. Colombia September 2017
11. Croatia September 2017
12. Curacao September 2017
13. Cyprus September 2017
14. Czech Republic September 2017
15. Denmark September 2017
16. Estonia September 2017
17. Faroe Islands September 2017
18. Finland September 2017
19. France September 2017
20. Germany September 2017
21. Gibraltar September 2017
22. Greece September 2017
23. Guernsey September 2017
24. Hungary September 2017
25. Iceland September 2017
26. Ireland September 2017
27. Isle of man September 2017
28. Italy September 2017
29. Jersey September 2017
30. Korea September 2017
31. Latvia September 2017
32. Liechtenstein September 2017
33. Lithuania September 2017
34. Luxembourg September 2017
35. Malta September 2017
36. Mauritius September 2017
37. Mexico September 2017
38. Montserrat September 2017
39. Netherlands September 2017
40. Norway September 2017
41. Poland September 2017
42. Portugal September 2017
43. Romania September 2017
44. San Marino September 2017
45. Slovak republic September 2017
46. Slovenia September 2017
47. South Africa September 2017
48. Spain September 2017
49. Sweden September 2017
50. Turks & Caicos Islands September 2017
51. United Kingdom September 2017
Second phase : countries that undertake first exchanges by 2018
Albania, Andorra, Antigua and Barbuda, Aruba, Australia, Austria, The Bahamas, Belize, Brazil, Brunei Darussalam, Canada, China, Costa Rica, Grenada, Hong Kong (China), Indonesia, Israel, Japan, Marshall Islands, Macao (China), Malaysia, Monaco, New Zealand, Qatar, Russia, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Samoa, Saudi Arabia, Singapore, Sint Maarten, Switzerland, Turkey, United Arab Emirates
Countries that have not indicated a timeline or that have not yet committed
Bahrain, Cook Islands, Nauru, Panama, Vanuatu
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