Based on these findings it was concluded that Türkiye is partially meeting expectations in relation to sorting, preparing and validating the information. However, significant issues have been identified, including with respect to the technical requirements. Türkiye should therefore continue its implementation process accordingly, including by addressing the recommendations made.
Recommendations:
Türkiye should continue to work with its exchange partners to address the issues raised.
Türkiye 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, Türkiye linked to the CTS.
Based on these findings it was concluded that Türkiye is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Türkiye 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:
Seven exchange partners highlighted delays in the sending of information by Türkiye (representing 10% of its partners). This represents a very high proportion of exchange partners. It was noted that Türkiye successfully addressed all of the issues and sent the information as soon as possible thereafter.
Based on these findings it was concluded that, overall, Türkiye is meeting expectations in relation to exchanging the information in a timely manner. It was also noted that there is room for improvement with respect to sending information to all exchange partners in a timely manner. Türkiye is encouraged to continue to ensure the ongoing effectiveness of its implementation, including by addressing the recommendation made.
Recommendations:
Türkiye should ensure that it sends information to all of its partners in a timely manner.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Türkiye’s exchange partners did not raise any concerns with respect to Türkiye’s use of the agreed transmission methods and therefore with Türkiye’s implementation of this requirement.
Based on these findings it was concluded that Türkiye is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Türkiye 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:
Eight exchange partners highlighted delays in the sending of status messages by Türkiye, representing 9% of its partners. This represents a relatively high proportion of partners and has not improved over time. It was noted that Türkiye appears to be successfully addressing the issues to ensure that status messages are sent in accordance with the requirements.
Based on these findings it was concluded that, overall, Türkiye is meeting expectations in relation to the receipt of the information. It was also noted that there is room for improvement with respect to the sending of status messages in a timely manner when information is received from an exchange partner. Türkiye is encouraged to continue to ensure the ongoing effectiveness of its implementation, including by addressing the recommendation made.
Recommendations:
Türkiye should ensure that it sends status messages to all of its exchange partners in a timely manner.
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:
While it is unclear whether Türkiye’s approach will ensure that corrected, amended or additional information is provided in a timely manner, it has not been tested and no such concerns were raised by Türkiye’s exchange partners and therefore with respect to Türkiye’s implementation of these requirements.
Based on these findings it was concluded that Türkiye appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information.
Recommendations:
No recommendations made.