|
Albania |
|
Albania does not yet have the necessary information gathering process in place. |
Albania is recommended to put in place an effective information gathering process to identify all potential exchange jurisdictions for future rulings on preferential regimes and to implement a review and supervision mechanism, as soon as possible. |
|
Albania does not yet have a process to complete the templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
Albania is recommended to continue to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework. |
|
Andorra |
|
Andorra still experiences difficulties in identifying all potential exchange jurisdictions for future rulings. |
Andorra is recommended to continue its efforts to ensure that all potential exchange jurisdictions are identified swiftly for all future rulings. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Andorra is still developing a process to ensure that the information is completed in the required form and exchanges are performed in accordance with the timelines. |
Andorra is recommended to continue its efforts to put in place the necessary process to complete the information in the form of Annex C of the Action 5 Report, to ensure that information is submitted to the Competent Authority without undue delay and exchanges are performed in accordance with the timelines. These recommendations remain unchanged since the 2017, 2018, 2019 and 2020 peer review reports but since the 2019 peer review report they are targeted to specific aspects of the ToR that still need to be put in place. |
|
Angola |
|
Angola has not yet finalised the steps to have in place its necessary information and gathering process. |
Angola is recommended to finalise its information gathering process for identifying all past and future rulings and all potential exchange jurisdictions, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Angola has not yet finalised the steps to have effective compulsory spontaneous exchange of information on the tax rulings within the scope of the transparency framework. |
Angola is recommended to continue to put in place a domestic legal framework allowing spontaneous exchange of information on rulings and to continue its efforts to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Antigua and Barbuda |
|
|
No recommendations are made. |
|
Argentina |
|
|
No recommendation are made. |
|
Armenia |
|
Armenia is in the process to finalise the information gathering process and to put in place a system for the identification and registration of issued tax rulings.
|
Armenia is recommended to continue its efforts to finalise and have in place the necessary information gathering process for identifying all relevant rulings and potential exchange jurisdictions, as soon as possible. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Armenia does not have a process to complete the templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
Armenia is recommended to continue its efforts to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework as soon as possible. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Aruba |
|
|
No recommendations are made. |
|
Australia |
|
|
No recommendations are made. |
|
Austria |
|
|
No recommendations are made. |
|
Barbados |
|
|
No recommendations are made. |
|
Belgium |
|
|
No recommendations are made. |
|
Benin |
|
Benin has not finalised the steps to have in place its necessary information gathering process, with a review and supervision mechanism. |
Benin is recommended to finalise its information gathering process for identifying all relevant rulings and all potential exchange jurisdictions, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Benin has not yet finalised the steps to have effective compulsory spontaneous exchange of information on the tax rulings within the scope of the transparency framework. |
Benin is recommended to continue to put in place a domestic legal framework allowing spontaneous exchange of information on rulings and to continue its efforts to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Bosnia and Herzegovina |
|
Bosnia and Herzegovina does not have specific mechanisms in place for identifying relevant rulings and potential exchange jurisdictions within the scope of the transparency framework as well as for reviewing and supervising that all relevant information is captured adequately. |
Bosnia and Herzegovina is recommended to put in place its information gathering process for identifying all past and future rulings and all potential exchange jurisdictions, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the prior year’s peer review report. |
|
Bosnia and Herzegovina does not yet have the necessary domestic legal basis to exchange information spontaneously and a process for completing the templates in a timely way. |
Bosnia and Herzegovina is recommended to put in place a domestic legal framework allowing spontaneous exchange of information on rulings and to ensure the timely exchange of information on rulings in the form required by the transparency framework, as soon as possible. This recommendation remains unchanged since the prior year’s peer review report. |
|
Botswana |
|
Botswana does not have a review and supervision mechanism in place. |
Botswana is recommended to put in place a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Botswana does not yet have the necessary legal framework in place for exchanging information on rulings and a process in place to ensure the timely exchange of information on rulings in the form required by the transparency framework. |
Botswana is recommended to continue its efforts to put in place a domestic legal framework allowing spontaneous exchange of information on rulings and to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Brazil |
|
|
No recommendations are made. |
|
Brunei Darussalam |
|
|
No recommendations are made. |
|
Burkina Faso |
|
Burkina Faso has not taken all measures to put in place the required information gathering process. |
Burkina Faso is recommended to finalise its information gathering process and implement a review and supervision mechanism as soon as possible. This recommendation remains unchanged since the prior year’s peer review report. |
|
Burkina Faso has not yet put in place the process to develop templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
Burkina Faso is recommended to establish a process to develop templates on relevant rulings and ensure that information on these rulings is exchanged in a timely manner and in the format required by the transparency framework. This recommendation remains unchanged since the prior year’s peer review report. |
|
Cabo Verde |
|
Cabo Verde does not have a process to complete the templates on relevant rulings and to make them available to the Competent Authority for exchange of information. |
Cabo Verde is recommended to continue its efforts to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework as soon as possible. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Canada |
|
|
No recommendations are made. |
|
Chile |
|
|
No recommendations are made. |
|
China (People's Republic of) |
|
|
No recommendations are made. |
|
Colombia |
|
|
No recommendations are made. |
|
Congo |
|
It is not known whether Congo has finalised the steps to have in place its necessary information and gathering process. |
Congo is recommended to finalise its information gathering process, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
It is not known whether Congo has finalised the steps to have effective compulsory spontaneous exchange of information on the tax rulings within the scope of the transparency framework. |
Congo is recommended to continue to put in place a domestic legal framework allowing spontaneous exchange of information on rulings and to continue its efforts to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Costa Rica |
|
|
No recommendations are made. |
|
Croatia |
|
|
No recommendations are made. |
|
Curaçao |
|
The information gathering process is still underway in Curaçao with respect to past and future rulings within the scope of the transparency framework and the classification of these rulings under each category. |
Curaçao is recommended to finalise its information gathering process for identifying all past and future rulings within the scope of the transparency framework as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Curaçao experienced delays in exchanging information on past and future rulings. |
Curaçao is recommended to continue its efforts to ensure that all information on past and future rulings is exchanged as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Czech Republic |
|
The Czech Republic experienced delays in the exchange of information on future rulings due to the application of the timelines set out in the EU Directive 2011/16/EU. |
The Czech Republic is recommended to ensure that all information on future rulings is exchanged as soon as possible. The Czech Republic also received a recommendation on timely exchange of information on rulings in the 2017, 2018 and 2020 peer review reports. |
|
Democratic Republic of the Congo |
|
It is not known whether the Democratic Republic of the Congo has put in place the necessary information and gathering process. |
The Democratic Republic of the Congo is recommended to finalise its information gathering process, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2020 peer review report. |
|
It is not known whether the Democratic Republic of the Congo has put in place an effective compulsory spontaneous exchange of information on the tax rulings within the scope of the transparency framework. |
The Democratic Republic of the Congo is recommended to continue to put in place a domestic legal framework allowing spontaneous exchange of information on rulings and to continue its efforts to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2020 peer review report. |
|
Denmark |
|
|
No recommendations are made. |
|
Dominican Republic |
|
|
No recommendations are made. |
|
Egypt |
|
Egypt has not yet identified all potential exchange jurisdictions for both past and future rulings and does not have a review and supervision mechanism in place to ensure that all relevant information on the identification of rulings and potential exchange jurisdictions is captured adequately. |
Egypt is recommended to continue its efforts to identify all potential exchange jurisdictions for both past and future rulings and to implement a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 review reports. |
|
Egypt does not have in place a process to ensure the timely exchange of information on rulings in the form required by the transparency framework. |
Egypt is recommended to swiftly implement its process to complete the templates on relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Estonia |
|
|
No recommendations are made. |
|
Eswatini |
|
Eswatini is currently taking steps to ensure the identification of all relevant rulings and all potential exchange jurisdictions as well as to have a review and supervision mechanism under the transparency framework. |
Eswatini is recommended to put in place its information gathering process for identifying all relevant rulings and all potential exchange jurisdictions, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the prior year’s peer review report. |
|
Eswatini is currently taking steps to put a process in place for the completion and exchange of information on rulings in accordance with the form and timelines required by the transparency framework. |
Eswatini is recommended to develop a process to complete the templates on relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework. This recommendation remains unchanged since the prior year’s peer review report. |
|
Faroe Islands |
|
The Faroe Islands does not yet have its necessary information and gathering process in place. |
The Faroe Islands is recommended to put in place an effective information gathering process to identify all relevant future rulings and all potential exchange jurisdictions and to implement a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
The Faroe Islands does not have a process to complete the templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
The Faroe Islands is recommended to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework going forward. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Finland |
|
|
No recommendations are made. |
|
France |
|
France did not identify or exchange information on new entrants to the IP regime. |
France is recommended to identify and exchange information on all new entrants to the IP regime. This recommendation remains unchanged since the 2016, 2017, 2018, 2019 and 2020 peer review reports. |
|
Gabon |
|
Gabon has not finalised the steps to have in place its necessary information gathering process, with a review and supervision mechanism. |
Gabon is recommended to finalise its information gathering process for identifying all relevant rulings and all potential exchange jurisdictions, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Gabon has not finalised the steps to put in place a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. |
Gabon is recommended to continue its efforts to put in place a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Georgia |
|
|
No recommendations are made. |
|
Germany |
|
|
No recommendations are made. |
|
Gibraltar |
|
|
No recommendations are made. |
|
Greece |
|
|
No recommendations are made. |
|
Grenada |
|
Grenada has not put in place the necessary information gathering process. |
Grenada is recommended to finalise its information gathering process for identifying all future rulings and potential exchange jurisdictions, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Grenada does not have a process to complete the templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
Grenada is recommended to develop a process to complete the templates on relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Guernsey |
|
|
No recommendations are made. |
|
Hong Kong (China) |
|
|
No recommendations are made. |
|
Hungary |
|
Hungary did not yet apply the “best efforts approach” to identify potential exchange jurisdictions for all past rulings. |
Hungary is recommended to continue to apply the “best efforts approach” to identify potential exchange jurisdictions for all past rulings. This recommendation remains unchanged since the 2016, 2017, 2018, 2019 and 2020 peer review reports. |
|
Iceland |
|
|
No recommendations are made. |
|
India |
|
India experienced delays in the exchange of information on future APAs. |
India is recommended to continue its efforts to ensure that all information on future APAs is exchanged as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Indonesia |
|
|
No recommendations are made. |
|
Ireland |
|
|
No recommendations are made. |
|
Isle of Man |
|
|
No recommendations are made. |
|
Israel |
|
|
No recommendations are made. |
|
Italy |
|
|
No recommendations are made. |
|
Jamaica |
|
|
No recommendations are made. |
|
Japan |
|
|
No recommendations are made. |
|
Jersey |
|
|
No recommendations are made. |
|
Jordan |
|
Jordan does not have specific mechanisms in place for identifying relevant rulings and potential exchange jurisdictions within the scope of the transparency framework as well as for reviewing and supervising that all relevant information is captured adequately. |
Jordan is recommended to ensure that it has put in place an effective information gathering process to identify all relevant rulings and potential exchange jurisdictions, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Jordan does not yet have the necessary domestic legal basis to exchange information spontaneously and a process to exchange information on rulings in the required format and timelines. |
Jordan is recommended to put in place a domestic legal framework allowing spontaneous exchange of information on the relevant tax rulings and to ensure the timely exchange of information on rulings in the form required by the transparency framework, as soon as possible. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Jordan has not identified information on new entrants to the Development zone IP regime during the relevant period, and has not exchanged information on these taxpayers. |
Jordan is recommended to identify information and to put in place a domestic legal framework allowing spontaneous exchange of information on all new entrants to the IP regime, as soon as possible. This recommendation remains unchanged since the prior year’s peer review report. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Kazakhstan |
|
Kazakhstan has not yet finalised the steps to have in place its necessary information and gathering process. |
Kazakhstan is recommended to finalise its information gathering process, with a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Kazakhstan has not yet finalised the steps to have effective compulsory spontaneous exchange of information on the tax rulings within the scope of the transparency framework. |
Kazakhstan is recommended to continue to put in place a domestic legal framework allowing spontaneous exchange of information on rulings and to continue its efforts to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Kenya |
|
|
No recommendations are made. |
|
Korea |
|
|
No recommendations are made. |
|
Latvia |
|
|
No recommendations are made. |
|
Liberia |
|
Liberia does not yet have the necessary information gathering process in place. |
Liberia is recommended to ensure that it has put in place an effective information gathering process to identify all relevant past and future rulings and all potential exchange jurisdictions and to implement a review and supervision mechanism, as soon as possible. |
|
Liberia does not yet have a process to complete the templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
Liberia is recommended to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework going forward. |
|
Liechtenstein |
|
|
No recommendations are made. |
|
Lithuania |
|
|
No recommendations are made. |
|
Luxembourg |
|
|
No recommendations are made. |
|
Malaysia |
|
Malaysia experienced difficulties in identifying all potential exchange jurisdictions for future rulings. |
Malaysia is recommended to continue its efforts to ensure that all potential exchange jurisdictions are identified swiftly for all future rulings. This recommendation remains unchanged since the 2019 and 2020 year peer review reports. |
|
Malaysia experienced delays in the provision of rulings to the Competent Authority and did not undertake spontaneous exchange of information on all future tax rulings within the scope of the transparency framework during the year in review. |
Malaysia is recommended to continue its efforts to reduce the timeliness for providing the information on rulings to the Competent Authority and to complete the templates for all relevant future rulings and to ensure that the exchanges of information on future rulings occur as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Malta |
|
|
No recommendations are made. |
|
Mauritius |
|
|
No recommendations are made. |
|
Mexico |
|
|
No recommendations are made. |
|
Morocco |
|
|
No recommendations are made. |
|
Namibia |
|
Namibia does not yet have the necessary information gathering process in place. |
Namibia is recommended to ensure that it has put in place an effective information gathering process to identify all relevant past and future rulings and all potential exchange jurisdictions and to implement a review and supervision mechanism, as soon as possible. This recommendation remains unchanged since the 2020 peer review. |
|
Namibia does not yet have a process to complete the templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
Namibia is recommended to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework going forward. This recommendation remains unchanged since the 2020 peer review. |
|
Netherlands |
|
The Netherlands experienced delays in the provision of rulings to the competent authority. |
The Netherlands is recommended to ensure that information is made available to the competent authority without undue delay. This recommendation remains unchanged since the prior year’s peer review report. |
|
New Zealand |
|
|
No recommendations are made. |
|
Nigeria |
|
Nigeria does not yet have the necessary information gathering process in place. |
Nigeria is recommended to ensure that it has put in place an effective information gathering process to identify all relevant past and future rulings and all potential exchange jurisdictions and to implement a review and supervision mechanism, as soon as possible. |
|
Nigeria does not yet have a process to complete the templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
Nigeria is recommended to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework going forward. |
|
Norway |
|
|
No recommendations are made. |
|
Pakistan |
|
Pakistan is taking steps to put the necessary information gathering process in place. |
Pakistan is recommended to ensure that it has put in place an effective information gathering process to identify all relevant past and future rulings and all potential exchange jurisdictions and to implement a review and supervision mechanism, as soon as possible. |
|
Pakistan is taking steps to put a process in place to complete the templates on relevant rulings, to make them available to the Competent Authority for exchange of information, and to exchange them with relevant jurisdictions. |
Pakistan is recommended to develop a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework going forward. |
|
Peru |
|
|
No recommendations are made. |
|
Philippines |
|
The Philippines does not currently collect information on all potential exchange jurisdictions, particularly the ultimate parent company for past rulings. |
The Philippines is recommended to apply the “best efforts approach” to identify potential exchange jurisdictions for all past rulings. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
The Philippines does not currently collect information on all potential exchange jurisdictions, particularly the ultimate parent company for future rulings. |
The Philippines is recommended to ensure that all potential exchange jurisdictions are identified swiftly for future rulings. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
The Philippines does not yet have a process in place to ensure the timely exchange of information on rulings in the form required by the transparency framework. |
The Philippines is recommended to continue its efforts to put in place a process to complete the templates for all relevant rulings and to ensure that the exchanges of information on rulings occur as soon as possible. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
|
Poland |
|
|
No recommendations are made. |
|
Portugal |
|
|
No recommendations are made. |
|
Qatar |
|
|
No recommendations are made. |
|
Romania |
|
|
No recommendations are made. |
|
Saint Kitts and Nevis |
|
|
No recommendations are made. |
|
Saint Lucia |
|
Saint Lucia does not require taxpayers to provide all necessary information to identify all potential exchange jurisdictions for future rulings. |
Saint Lucia is recommended to ensure that all potential exchange jurisdictions are identified swiftly for all future rulings. This recommendation remains unchanged since the 2018, 2019 and 2020 peer review reports. |
|
Samoa |
|
|
No recommendations are made. |
|
San Marino |
|
|
No recommendations are made. |
|
Senegal |
|
|
No recommendations are made. |
|
Seychelles |
|
|
No recommendations are made. |
|
Singapore |
|
|
No recommendations are made. |
|
Sint Maarten |
|
|
No recommendations are made. |
|
Slovak Republic |
|
|
No recommendations are made. |
|
Slovenia |
|
|
No recommendations are made. |
|
South Africa |
|
|
No recommendations are made. |
|
Spain |
|
|
No recommendations are made. |
|
Sri Lanka |
|
|
No recommendations are made. |
|
Sweden |
|
|
No recommendations are made. |
|
Switzerland |
|
Switzerland experienced delays in the exchange of information on past and future rulings. |
Switzerland is recommended to continue to ensure that all information on past and future rulings is exchanged as soon as possible. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Thailand |
|
Thailand does not yet have the necessary legal framework in place for exchanging information on rulings. |
Thailand is recommended to finalise the amendments to put the domestic legal basis in place to commence exchanges. This recommendation remains unchanged since the 2019 and 2020 peer review reports. |
|
Türkiye |
|
|
No recommendations are made. |
|
Ukraine |
|
|
No recommendations are made. |
|
United Kingdom |
|
|
No recommendations are made. |
|
United States |
|
|
No recommendations are made. |
|
Uruguay |
|
|
No recommendations are made. |
|
Viet Nam |
|
It is not known whether Viet Nam developed a process for completion of templates and exchange of information on rulings. |
Viet Nam is recommended to develop a process to complete the templates on relevant rulings and to ensure that the exchanges of information on rulings occur in accordance with the form and timelines under the transparency framework. This recommendation remains unchanged since the 2017, 2018, 2019 and 2020 peer review reports. |
