In response to the international community’s demand to advance global transparency and exchange of information for tax purposes, demonstrated by the calls from the G20, the OECD developed the AEOI Standard in 2014. All members of the Global Forum, aside from developing countries that did not host a financial centre, were asked to commit to automatically exchanging financial information under the AEOI Standard by 2017 or 2018. This section contains the latest information on the timeliness of the implementation of the AEOI Standard by all jurisdictions.
Peer Review of the Automatic Exchange of Financial Account Information 2021
1. Monitoring the implementation of the AEOI Standard
Abstract
Following a call by the G20, the OECD, working with G20 countries, developed the AEOI Standard in 2014. The Global Forum was immediately tasked by the G20 with monitoring the implementation of the AEOI Standard worldwide. As a first step the Global Forum put in place a commitment process to facilitate the widespread application of the AEOI Standard, based on a level playing field.
The AEOI commitment process
As soon as the AEOI Standard was developed, the Global Forum recognised the potential benefits of its rapid and widespread implementation, alongside its existing standard of exchange of information on request (EOIR). The Global Forum therefore immediately put in place a process to promote the global implementation of the AEOI Standard. Consequently, all Global Forum members, except for developing countries that did not host a financial centre, were asked to commit to:
implement the AEOI Standard;
exchange information with all Interested Appropriate Partners (all jurisdictions interested in receiving information from a jurisdiction and that meet the expected standards in relation to confidentiality and data safeguards); and
commence exchanges in 2017 or 2018.
Forty-nine “early adopter” jurisdictions quickly committed to exchange information under the AEOI Standard in 2017 and a further 51 jurisdictions in 2018. Another 20 jurisdictions have since committed to implementing the AEOI Standard in time to start exchanging by 2024. This includes 14 developing countries not asked to commit to the AEOI Standard to a specific timeline, but that want to access the benefits the AEOI Standard has to offer. It also includes a further three jurisdictions identified through the Global Forum’s “jurisdiction of relevance” process established to maintain a level playing field, which subsequently voluntarily committed to implement the AEOI Standard.
Further details on the individual commitments made are contained in the tables 1.1 to 1.3 below.
Monitoring the timeliness of delivery
The Global Forum has since monitored the timeliness of the delivery of each aspect of the implementation process. The key milestones relate to:
putting in place a domestic legislative framework to require Financial Institutions to collect and report the information for exchange that is in accordance with the detailed due diligence and reporting rules contained in the AEOI Standard;
putting in place an international legal framework permitting the automatic exchange of information with a jurisdiction’s Interested Appropriate Partners. This includes an underlying legal basis and an administrative agreement containing the details of the exchanges – the vast majority of jurisdictions are using the multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Convention) along with the CRS Multilateral Competent Authority Agreement (or CRS MCAA)1; and
a technical infrastructure to receive the information from Financial Institutions and to process and transmit it to a jurisdiction’s exchange partners. All jurisdictions use the Common Transmission System (CTS), developed and procured by the OECD and managed by the Global Forum.
Further details on each jurisdiction’s timeliness in meeting these milestones are contained in the tables 1.2 to 1.4 below.
Delivery of the commitments
Table 1.1 presents details of the exchanges that took place in 2020 and 2021. The widespread delivery of the exchanges shows that the overwhelming majority of jurisdictions implemented the necessary legal and technical frameworks, in accordance with their commitments.
97% of the jurisdictions have delivered on their commitment to exchange information under the AEOI Standard.
Table 1.1. Jurisdictions that have exchanged information in 2020 and 2021
Jurisdiction |
Year of commitment to first exchanges |
Number of partners to which the data relating to 2019 was sent in 2020 |
Number of partners to which the data relating to 2020 was sent in 2021 |
---|---|---|---|
2021 |
59 |
69 |
|
2. Andorra |
2018 |
69 |
60 |
3. Anguilla |
2017 |
52 |
55 |
4. Antigua and Barbuda2 |
2018 |
30 |
- |
5. Argentina |
2017 |
71 |
76 |
6. Aruba |
2018 |
66 |
64 |
7. Australia |
2018 |
70 |
72 |
8. Austria |
2018 |
68 |
71 |
9. Azerbaijan6 |
2018 |
48 |
63 |
10. Bahamas |
2018 |
56 |
58 |
11. Bahrain |
2018 |
59 |
63 |
12. Barbados |
2018 |
61 |
64 |
13. Belgium |
2017 |
72 |
77 |
14. Belize |
2018 |
64 |
63 |
15. Bermuda |
2017 |
60 |
64 |
16. Brazil |
2018 |
69 |
76 |
17. British Virgin Islands |
2017 |
67 |
65 |
18. Brunei Darussalam |
2018 |
33 |
41 |
19. Bulgaria |
2017 |
71 |
72 |
20. Canada |
2018 |
57 |
66 |
21. Cayman Islands |
2017 |
70 |
73 |
22. Chile |
2018 |
69 |
72 |
23. China (People’s Republic of) |
2018 |
69 |
75 |
24. Colombia |
2017 |
70 |
77 |
25. Cook Islands |
2018 |
68 |
68 |
26. Costa Rica |
2018 |
69 |
71 |
27. Croatia |
2017 |
70 |
75 |
28. Curaçao |
2018 |
66 |
51 |
29. Cyprus |
2017 |
72 |
74 |
30. Czech Republic |
2017 |
66 |
74 |
31. Denmark |
2017 |
73 |
76 |
32. Dominica3 |
2018 |
- |
1 |
33. Ecuador6 |
2021 |
N/A |
44 |
34. Estonia |
2017 |
69 |
73 |
35. Faroe Islands |
2017 |
67 |
73 |
36. Finland |
2017 |
70 |
77 |
37. France |
2017 |
68 |
71 |
38.Including New Caledonia |
2020 |
29 |
33 |
39. Germany |
2017 |
68 |
74 |
40. Ghana6 |
2019 |
64 |
62 |
41. Gibraltar |
2017 |
69 |
72 |
42. Greece |
2017 |
69 |
74 |
43. Greenland |
2018 |
69 |
77 |
44. Grenada |
2018 |
65 |
61 |
45. Guernsey |
2017 |
70 |
73 |
46. Hong Kong (China) |
2018 |
50 |
67 |
47. Hungary |
2017 |
72 |
71 |
48. Iceland |
2017 |
67 |
70 |
49. India |
2017 |
68 |
72 |
50. Indonesia |
2018 |
69 |
72 |
51. Ireland |
2017 |
73 |
77 |
52. Isle of Man |
2017 |
68 |
75 |
53. Israel |
2018 |
61 |
67 |
54. Italy |
2017 |
71 |
75 |
55. Japan |
2018 |
70 |
75 |
56. Jersey |
2017 |
69 |
72 |
57. Kazakhstan2 |
2021 |
N/A |
- |
58. Korea |
2017 |
70 |
74 |
59. Kuwait |
2019 |
67 |
62 |
60. Latvia |
2017 |
69 |
75 |
61. Lebanon2 |
2018 |
50 |
- |
62. Liechtenstein |
2017 |
68 |
75 |
63. Lithuania |
2017 |
70 |
70 |
64. Luxembourg |
2017 |
72 |
77 |
65. Macau (China) |
2018 |
60 |
67 |
66. Malaysia |
2018 |
65 |
68 |
67. Malta |
2017 |
73 |
73 |
68. Marshall Islands |
2018 |
59 |
60 |
69. Mauritius |
2018 |
69 |
74 |
70. Mexico |
2017 |
67 |
73 |
71. Monaco |
2018 |
63 |
65 |
72. Montserrat2 |
2017 |
60 |
- |
73. Nauru |
2018 |
69 |
73 |
74. Netherlands |
2017 |
68 |
70 |
75. New Zealand |
2018 |
66 |
73 |
76. Nigeria6 |
2020 |
25 |
63 |
77. Norway |
2017 |
71 |
75 |
78. Oman |
2020 |
28 |
28 |
79. Pakistan6 |
2018 |
57 |
61 |
80. Panama |
2018 |
63 |
66 |
81. Peru6 |
2020 |
15 |
45 |
82. Poland |
2017 |
71 |
74 |
83. Portugal |
2017 |
71 |
76 |
84. Qatar |
2018 |
49 |
58 |
85. Romania |
2017 |
67 |
71 |
86. Russia |
2018 |
63 |
68 |
87. Saint Kitts and Nevis |
2018 |
57 |
59 |
88. Saint Lucia |
2018 |
65 |
68 |
89. Saint Vincent and the Grenadines4 |
2018 |
- |
- |
90. Samoa |
2018 |
64 |
65 |
91. San Marino |
2017 |
68 |
71 |
92. Saudi Arabia |
2018 |
68 |
74 |
93. Seychelles |
2017 |
63 |
25 |
94. Singapore |
2018 |
66 |
70 |
95. Slovak Republic |
2017 |
68 |
77 |
96. Slovenia |
2017 |
72 |
78 |
97. South Africa |
2017 |
68 |
76 |
98. Spain |
2017 |
71 |
78 |
99. Sweden |
2017 |
70 |
73 |
100. Switzerland |
2018 |
66 |
72 |
101. Turkey |
2018 |
34 |
55 |
102. Turks and Caicos Islands5 |
2017 |
63 |
58 |
103. United Arab Emirates |
2018 |
68 |
70 |
104. United Kingdom |
2017 |
70 |
72 |
105. Uruguay |
2018 |
70 |
74 |
106. Vanuatu |
2018 |
53 |
52 |
Notes: The number of exchanges jurisdictions undertake each year tend to increase due to the expansion of exchange networks. However, fluctuations are observed in some cases due to technical issues when sending the information. This can lead to rejections by exchange partners of the information sent. In such cases, jurisdictions are expected to address the issues and send/re-send the information.
The United States has undertaken automatic information exchanges pursuant to FATCA from 2015 and entered into intergovernmental agreements (IGAs) with other jurisdictions to do so. The Model 1A IGAs entered into by the United States acknowledge the need for the United States to achieve equivalent levels of reciprocal automatic information exchange with partner jurisdictions. They also include a political commitment to pursue the adoption of regulations and to advocate and support relevant legislation to achieve such equivalent levels of reciprocal automatic exchange.
1. Albania voluntarily committed to 2021, but started exchanges in 2020.
2. These jurisdictions are delayed in undertaking the exchanges that should have taken place in 2021. They are expected to carry out the exchanges in the near future.
3. Dominica was delayed in undertaking the exchanges that should have taken place in 2018, 2019 and 2020. It has been able to commence exchanges with one partner so far in 2021 and is expected to carry out the remaining exchanges in the near future.
4. Due to technical difficulties, Saint Vincent and the Grenadines was delayed in undertaking the exchanges that should have taken place in 2020 and 2021.
5. Due to technical difficulties, the Turks and Caicos Islands was delayed in undertaking the exchanges that should have taken place in 2019.
6. These jurisdictions are developing countries that were not asked to commit to implementing the AEOI Standard to a particular timeline, but did so voluntarily.
While recognising the widespread successes in the fulfilment of the commitments made, some jurisdictions have not yet delivered. A fully effective AEOI Standard requires a level playing field and the Global Forum therefore continues to work closely with these jurisdictions to facilitate the delivery of their commitments.
Table 1.2 shows the jurisdictions that are late in putting in place the necessary legal frameworks to implement the AEOI Standard, namely Sint Maarten and Trinidad and Tobago.
Table 1.2. Jurisdictions that have not yet exchanged information because their legal implementation is ongoing
Jurisdiction |
Year of commitment to first exchanges |
Status |
---|---|---|
1. Sint Maarten |
2018 |
Domestic and international legal frameworks not in place |
2. Trinidad and Tobago |
2018 |
Domestic and international legal frameworks not in place |
Table 1.3 shows the jurisdictions that have in place the legal frameworks to implement the AEOI Standard but that have not put in place the technical requirements for exchange, namely Niue.
Table 1.3. Jurisdictions that have not yet exchanged information because their technical implementation is ongoing
Jurisdiction |
Year of commitment to first exchanges |
Status |
---|---|---|
1. Niue |
2018 |
Has not linked into the CTS |
Commitments to commence exchanges in the future
A further twelve jurisdictions are committed to starting exchanges in the coming years. These are set out in Table 1.4 below.
Table 1.4. Jurisdictions committed to commencing exchanges from 2022 onwards
1. Developing countries that do not host a financial centre and that were not asked to commit to a specific date to exchange information, but that have done so voluntarily.
2. Jordan, Montenegro and Thailand were identified through the Global Forum process aimed at identifying jurisdictions of relevance for the implementation of the AEOI Standard and subsequently voluntarily committed to implement the AEOI Standard.
Peer reviews of the quality of implementation
While the timeliness of implementation is critical, the full potential benefits of the AEOI Standard will only be delivered if the requirements are implemented in a complete and effective manner.
To ensure this, Global Forum conducts peer reviews with respect to the quality of the implementation of all aspects of the AEOI Standard. Chapter 2 contains further details in this regard.
Note
← 1. Details on each of the agreements in place can be found in Annex B.