As the political imperative to further address the problem of international tax evasion grew, the OECD and G20 developed the AEOI Standard. This was a major change in international tax transparency. All members of the Global Forum, aside from developing countries that did not host a financial centre, were consequently asked to commit to commence exchanging information under the AEOI Standard by 2017 or 2018, and many subsequent commitments to commence exchanges have also been made. 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 2022
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1. Monitoring the implementation of the AEOI Standard
Abstract
The OECD, working with G20 countries, developed the AEOI Standard in 2014. The G20 then asked the Global Forum to monitor the implementation of the AEOI Standard worldwide. As a first step, the Global Forum initiated a commitment process to ensure the widespread application of the AEOI Standard, based on a level playing field.
The AEOI commitment process
The Global Forum was quick to recognise the potential benefits of the rapid and widespread implementation of the AEOI Standard, to complement its existing standard of exchange of information on request (EOIR), to provide tax administrations with a powerful set of tools to ensure tax compliance. The Global Forum therefore immediately instigated a process to provide for the commitment of all of its members, except for developing countries that did not host a financial centre, to implement the AEOI Standard to specific timelines. Jurisdictions were asked to:
implement the AEOI Standard;
exchange information with all Interested Appropriate Partners (which are 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 commence the exchange information under the AEOI Standard in 2017, and a further 51 jurisdictions committed to commence exchanged in 2018. Another 21 jurisdictions have since committed to implement the AEOI Standard, with commencement dates ranging between 2019 and 2024. This includes four jurisdictions identified through the Global Forum’s “jurisdiction of relevance” process, established to maintain a level playing field and which subsequently voluntarily committed to implement the AEOI Standard. It also includes 17 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.
Further details on the individual commitments made are contained in Tables 1.1 and 1.2.
Monitoring the timeliness of delivery
Once the commitments are made, the Global Forum monitors the timeliness of the delivery of each aspect of the implementation process. The key milestones relate to:
putting in place a domestic legislative framework requiring Financial Institutions to collect and report the information for exchange in accordance with the due diligence and reporting rules contained in the AEOI Standard;
putting in place an international legal framework that permits the automatic exchange of information with a jurisdiction’s exchange partners. This consists of an underlying legal basis for the exchange and an administrative agreement containing the detailed specificities. In the overwhelming majority of cases this consists of the multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Convention), along with the Multilateral Competent Authority Agreement implementing the international framework for the AEOI Standard (or MCAA)1; and
establishing a technical infrastructure to receive the information from Financial Institutions and to process and transmit it to exchange partners. With respect to the transmissions, all jurisdictions use the Common Transmission System (CTS), developed and procured by the OECD and managed by the Global Forum.
Delivery of the commitments
Table 1.1 presents details of the numbers of partners to which information was successfully sent since 2018. It also includes instances where the necessary legal frameworks were in place containing an obligation on Reporting Financial Institutions to report information with respect to particular exchange partners, but where no relevant Reportable Accounts were identified (i.e. essentially a nil return).
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.
98% of the jurisdictions have delivered on their commitment to exchange information under the AEOI Standard.
Table 1.1. Jurisdictions that have exchanged information in each year from 2018 to 2022
Jurisdiction |
Year of commitment to first exchanges |
Number of partners to which the data relating to 2017 was sent in 2018 |
Number of partners to which the data relating to 2018 was sent in 2019 |
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 |
Number of partners to which the data relating to 2021 was sent in 2022 |
---|---|---|---|---|---|---|
2021 |
N/A |
N/A |
59 |
69 |
75 |
|
2. Andorra |
2018 |
39 |
59 |
69 |
62 |
67 |
3. Anguilla |
2017 |
4 |
52 |
52 |
55 |
- 6 |
4. Antigua and Barbuda |
2018 |
36 |
35 |
30 |
33 |
23 |
5. Argentina |
2017 |
56 |
67 |
71 |
76 |
78 |
6. Aruba |
2018 |
50 |
58 |
66 |
64 |
65 |
7. Australia |
2018 |
57 |
64 |
70 |
72 |
76 |
8. Austria |
2018 |
46 |
61 |
68 |
71 |
77 |
9. Azerbaijan1 |
2018 |
33 |
53 |
48 |
67 |
74 |
10. Bahamas |
2018 |
36 |
48 |
56 |
60 |
66 |
11. Bahrain |
2018 |
38 |
50 |
59 |
63 |
65 |
12. Barbados |
2018 |
57 |
53 |
61 |
64 |
62 |
13. Belgium |
2017 |
66 |
69 |
72 |
77 |
80 |
14. Belize |
2018 |
47 |
59 |
64 |
63 |
67 |
15. Bermuda |
2017 |
52 |
61 |
60 |
64 |
70 |
16. Brazil |
2018 |
56 |
67 |
69 |
76 |
76 |
17. British Virgin Islands |
2017 |
50 |
64 |
67 |
65 |
61 |
18. Brunei Darussalam |
2018 |
27 |
27 |
33 |
41 |
61 |
19. Bulgaria |
2017 |
60 |
65 |
71 |
73 |
77 |
20. Canada |
2018 |
56 |
59 |
57 |
66 |
65 |
21. Cayman Islands |
2017 |
57 |
64 |
70 |
73 |
73 |
22. Chile |
2018 |
48 |
63 |
69 |
72 |
71 |
23. China (People’s Republic of) |
2018 |
52 |
64 |
69 |
75 |
76 |
24. Colombia |
2017 |
60 |
65 |
70 |
77 |
77 |
25. Cook Islands |
2018 |
45 |
62 |
68 |
68 |
72 |
26. Costa Rica |
2018 |
49 |
67 |
69 |
71 |
07 |
27. Croatia |
2017 |
60 |
65 |
70 |
76 |
77 |
28. Curaçao |
2018 |
57 |
57 |
66 |
51 |
71 |
29. Cyprus |
2017 |
59 |
67 |
72 |
74 |
77 |
30. Czech Republic |
2017 |
60 |
60 |
66 |
74 |
80 |
31. Denmark |
2017 |
66 |
69 |
73 |
76 |
78 |
32. Dominica |
2018 |
0 |
0 |
0 |
56 |
65 |
33. Ecuador1 |
2021 |
N/A |
N/A |
N/A |
46 |
65 |
34. Estonia |
2017 |
62 |
66 |
69 |
73 |
74 |
35. Faroe Islands |
2017 |
57 |
67 |
67 |
73 |
72 |
36. Finland |
2017 |
66 |
69 |
70 |
77 |
81 |
37. France |
2017 |
62 |
66 |
68 |
71 |
73 |
38. Including New Caledonia |
2020 |
N/A |
N/A |
29 |
33 |
36 |
39. Germany |
2017 |
63 |
68 |
68 |
74 |
77 |
40. Ghana1 |
2019 |
N/A |
56 |
64 |
62 |
68 |
41. Gibraltar |
2017 |
51 |
59 |
69 |
72 |
73 |
42. Greece |
2017 |
67 |
68 |
69 |
74 |
76 |
43. Greenland |
2018 |
57 |
67 |
69 |
77 |
76 |
44. Grenada |
2018 |
55 |
54 |
65 |
61 |
59 |
45. Guernsey |
2017 |
61 |
64 |
70 |
73 |
78 |
46. Hong Kong (China) |
2018 |
36 |
45 |
50 |
67 |
71 |
47. Hungary |
2017 |
57 |
66 |
72 |
72 |
73 |
48. Iceland |
2017 |
59 |
64 |
67 |
70 |
73 |
49. India |
2017 |
60 |
67 |
68 |
74 |
77 |
50. Indonesia |
2018 |
59 |
66 |
69 |
72 |
77 |
51. Ireland |
2017 |
66 |
69 |
73 |
78 |
418 |
52. Isle of Man |
2017 |
57 |
64 |
68 |
75 |
78 |
53. Israel |
2018 |
41 |
55 |
61 |
67 |
71 |
54. Italy |
2017 |
64 |
67 |
71 |
76 |
75 |
55. Jamaica1 |
2022 |
N/A |
N/A |
N/A |
N/A |
11 |
56. Japan |
2018 |
55 |
67 |
70 |
75 |
77 |
57. Jersey |
2017 |
58 |
65 |
69 |
73 |
76 |
58. Kazakhstan3 |
2021 |
N/A |
N/A |
N/A |
39 |
57 |
59. Kenya1 |
2022 |
N/A |
N/A |
N/A |
N/A |
- 6 |
60. Korea |
2017 |
59 |
67 |
70 |
74 |
76 |
61. Kuwait2 |
2019 |
34 |
52 |
67 |
62 |
72 |
62. Latvia |
2017 |
56 |
66 |
69 |
75 |
78 |
63. Lebanon |
2018 |
27 |
59 |
50 |
60 |
- 6 |
64. Liechtenstein |
2017 |
50 |
60 |
68 |
75 |
74 |
65. Lithuania |
2017 |
63 |
66 |
70 |
70 |
75 |
66. Luxembourg |
2017 |
66 |
69 |
72 |
77 |
79 |
67. Macau (China) |
2018 |
36 |
48 |
60 |
67 |
70 |
68. Malaysia |
2018 |
42 |
64 |
65 |
69 |
73 |
69. Maldives1 |
2022 |
N/A |
N/A |
N/A |
N/A |
35 |
70. Malta |
2017 |
61 |
67 |
73 |
73 |
73 |
71. Marshall Islands |
2018 |
1 |
57 |
59 |
60 |
58 |
72. Mauritius |
2018 |
58 |
65 |
69 |
74 |
75 |
73. Mexico |
2017 |
60 |
67 |
67 |
73 |
75 |
74. Monaco |
2018 |
34 |
58 |
63 |
65 |
66 |
75. Montserrat |
2017 |
12 |
16 |
60 |
0 |
57 |
76. Nauru4 |
2018 |
No RFIs |
No RFIs |
No RFIs |
No RFIs |
No RFIs |
77. Netherlands |
2017 |
61 |
65 |
68 |
70 |
77 |
78. New Zealand |
2018 |
55 |
65 |
66 |
73 |
77 |
79. Nigeria1 |
2020 |
N/A |
N/A |
25 |
63 |
73 |
80. Niue4 |
2018 |
No RFIs |
No RFIs |
No RFIs |
No RFIs |
No RFIs |
81. Norway |
2017 |
64 |
68 |
71 |
75 |
77 |
82. Oman2 |
2020 |
N/A |
N/A |
28 |
28 |
39 |
83. Pakistan1 |
2018 |
40 |
55 |
57 |
61 |
55 |
84. Panama |
2018 |
32 |
62 |
63 |
67 |
68 |
85. Peru1 |
2020 |
N/A |
N/A |
15 |
45 |
61 |
86. Poland |
2017 |
66 |
69 |
71 |
74 |
76 |
87. Portugal |
2017 |
66 |
69 |
71 |
76 |
75 |
88. Qatar |
2018 |
9 |
49 |
49 |
58 |
59 |
89. Romania |
2017 |
59 |
65 |
67 |
71 |
77 |
90. Russia |
2018 |
50 |
58 |
63 |
69 |
No data |
91. Saint Kitts and Nevis |
2018 |
25 |
62 |
57 |
59 |
61 |
92. Saint Lucia |
2018 |
40 |
61 |
65 |
68 |
69 |
93. Saint Vincent and the Grenadines |
2018 |
65 |
56 |
0 |
0 |
21 |
94. Samoa |
2018 |
45 |
59 |
64 |
66 |
63 |
95. San Marino |
2017 |
57 |
63 |
68 |
71 |
74 |
96. Saudi Arabia |
2018 |
56 |
65 |
68 |
74 |
72 |
97. Seychelles |
2017 |
55 |
66 |
63 |
25 |
49 |
99. Singapore |
2018 |
50 |
63 |
66 |
70 |
75 |
99. Sint Maarten |
2018 |
0 |
0 |
0 |
0 |
49 |
100. Slovak Republic |
2017 |
62 |
67 |
68 |
77 |
77 |
101. Slovenia |
2017 |
64 |
69 |
72 |
78 |
80 |
102. South Africa |
2017 |
57 |
63 |
68 |
76 |
77 |
103. Spain |
2017 |
66 |
71 |
72 |
78 |
80 |
104. Sweden |
2017 |
61 |
66 |
70 |
73 |
78 |
105. Switzerland |
2018 |
36 |
62 |
66 |
72 |
73 |
106. Türkiye |
2018 |
1 |
1 |
34 |
55 |
73 |
107. Turks and Caicos Islands |
2017 |
44 |
0 |
63 |
67 |
68 |
108. United Arab Emirates |
2018 |
43 |
53 |
68 |
70 |
75 |
109. United Kingdom |
2017 |
62 |
68 |
70 |
72 |
76 |
110. Uruguay |
2018 |
59 |
67 |
70 |
74 |
77 |
111. Vanuatu |
2018 |
20 |
42 |
53 |
53 |
61 |
Notes:
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. The number of exchanges jurisdictions undertaken each year can fluctuate for a variety of reasons. They often increase due to new jurisdictions participating in the AEOI Standard, the expansion of exchange networks and delayed exchanges (which can be attributable to a prior year). They can also decrease, such as when delays occur or when technical difficulties arise (in the sending or receiving jurisdiction), which can lead to the rejection of files exchanged. Where delays occur, or technical difficulties arise, jurisdictions are expected to address the issues and send/re-send the information.
1. These jurisdictions are developing countries that were not asked to commit to implementing the AEOI Standard to a particular timeline but did so voluntarily.
2. Developed countries that joined the Global Forum after the commitment process was conducted in 2014. They were therefore asked to commit to a particular timeline upon joining.
3. This jurisdiction was 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.
4. As established through the peer review process, there are no Reporting Financial Institutions (RFIs) located in these jurisdictions.
5. Albania voluntarily committed to commence exchanges in 2021 but did so in 2020.
6. These jurisdictions are delayed in undertaking the exchanges that should have taken place by the end of September 2022. They are expected to carry out the exchanges in the near future.
7. Costa Rica has temporarily suspended exchanges while it reviews its confidentiality and data safeguard arrangements.
8. Ireland is experiencing technical difficulties that are impacting some of its 2022 exchanges. They are currently being resolved and the number of 2022 exchanges is expected to increase in the near future.
Jurisdictions yet to commence exchanges as committed to
As set out above, the overwhelming majority of the jurisdictions that have committed to commence exchanges under that AEOI Standard have done so. This is a huge success. There still remains one jurisdiction – Trinidad and Tobago – that has not yet delivered as committed as it is still delayed in putting in place the required legal frameworks. A fully effective AEOI Standard requires a level playing field and the Global Forum therefore continues to work closely with Trinidad and Tobago to facilitate the delivery of its commitment.
Commitments to commence exchanges in the future
A further 10 jurisdictions are committed to starting exchanges in the coming years. These are set out in Table 1.2 below.
Table 1.2. Jurisdictions committed to commencing exchanges from 2023 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 potential benefits of the AEOI Standard will only be fully 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