Based on these findings it was concluded that the Netherlands is partially meeting expectations in relation to sorting, preparing and validating the information. However, significant issues have been identified, including with respect to routinely addressing issues reported by partners. The Netherlands should therefore continue its implementation process accordingly, including by addressing the recommendations made.
Recommendations:
The Netherlands should continue to work with its exchange partners to address the issues raised.
The Netherlands should review its systems and procedures for sorting, preparing and validating the information to send to its exchange partners, to ensure they meet the requirements of the AEOI Standard.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, the Netherlands linked to the CTS and the CCN, which is used for exchanges within the EU.
Based on these findings it was concluded that the Netherlands is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. The Netherlands is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
One exchange partner highlighted delays in the sending of information by the Netherlands. It was noted that the Netherlands successfully addressed all of the issues and sent the information as soon as possible thereafter.
Based on these findings it was concluded that the Netherlands is fully meeting expectations in relation to exchanging the information in a timely manner. The Netherlands is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from the Netherlands’ exchange partners did not raise any concerns with respect to the Netherlands’ use of the agreed transmission methods and therefore with the Netherlands’ implementation of this requirement.
Based on these findings it was concluded that the Netherlands is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. The Netherlands is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
Findings:
Two exchange partners highlighted delays in the sending of status messages by the Netherlands, representing 3% of its partners. It was noted that the Netherlands is successfully addressing the issues to ensure that status messages are sent in accordance with the requirements.
Based on these findings it was concluded that the Netherlands is fully meeting expectations in relation to the receipt of the information. The Netherlands is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
The Netherlands appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by the Netherlands’ exchange partners and therefore with respect to the Netherlands’ implementation of these requirements.
Based on these findings it was concluded that the Netherlands appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. The Netherlands is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.