Automatic Exchange of Information on Financial Accounts

3 November 2014, updated 5 November 2017

On 29 October 2014, 51 jurisdictions (countries and dependent territories) signed a multilateral agreement to automatically exchange information on financial accounts based on the multilateral convention. As of 02 November 2017, 44 jurisdictions more joined the multilateral agreement, making 95 jurisdictions in total. This is the first ever agreement to exchange this type of information automatically. All previously signed agreements concerning exchange of information on tax matters assume that the information is exchanged on request, namely relating to a specific tax investigation, either criminal or civil. Signing the agreement on automatic information exchange is a huge step to address the issues of international tax avoidance and evasion.

The information will be exchanged between the jurisdictions that signed the agreement under a single global standard on an annual basis. 49 jurisdictions committed to start the information exchange by 2017, 53 jurisdictions more - by 2018. While singing the Convention itself means only commitment of a signing jurisdiction to provide administrative assistance to other signed jurisdictions in tax matters, the automatic exchange is going to be based on bilateral agreements and the EU framework. As of November 2017, out of 102 jurisdictions, 32 jurisdictions don't have bilateral agreements with other jurisdictions to either send or to receive the information, and 12 jurisdictions more don't have such agreements to send the information.

Jurisdictions That Will Exchange Information

The financial accounts information will be exchanged only between the countries and the territories for which the convention is in force and in effect.

To clarify the information flows, consider the examples:

  1. Both Jurisdiction A and Jurisdiction B signed the convention.
    These jurisdictions will exchange the information. The Jurisdiction A will report to the Jurisdiction B, the Jurisdiction B will report to the Jurisdiction A.
  2. Jurisdiction C signed the convention, Jurisdiction D didn't sign the convention.
    There will be no information exchange between the Jurisdiction C and Jurisdiction D. The Jurisdiction C will not report to the Jurisdiction D, and the Jurisdiction C will not report to the Jurisdiction D.

102 jurisdictions have made commitments to start exchanging the information on financial accounts by the end of 2018. The automatic exchange will be triggered by signing bilateral agreements and the EU framework (for EU member states). As of November 2017, 32 jurisdictions don't have bilateral agreements with other jurisdictions to either send or to receive the information, and 12 jurisdictions more don't have such agreements to send the information.

European Countries and Territories That Will Exchange Information

Several notes should be made about status of commitments of the European countries and territories:

Reporting Financial Institutions

The financial institutions that required to report are not only banks and custodians but also other financial institutions such as

Branches of Foreign Financial Institutions

Branches of foreign financial institutions operating in a jurisdiction that joined the convention, will report in this jurisdiction.

For example:

  A branch of Deutsche Bank operating in Luxembourg will report to competent authorities of Luxembourg rather than of Germany.

Branches of foreign financial institutions operating in a jurisdiction that didn't join the convention, will not report either in this jurisdiction or in their home jurisdiction.

For example:

  A branch of BNP Paribas operating in Bulgaria will not report either to Bulgarian or to French competent authorities because Bulgaria didn't sign the convention.

Reportable Accounts

Reportable accounts include accounts held by individuals and entities (which includes trusts and foundations).

Individual Accounts

Reportable Persons

An account held by an individual (individuals) is a reportable account if the account holder(s) is a tax resident (a resident for tax purposes) of a reportable jurisdiction. The account holder is called a reportable person.

Preexisting financial accounts held by individuals (accounts that existed before the jurisdiction signed the convention) will be reported as well as new financial accounts.

For example:

  1. If a citizen of the United Kingdom is a tax resident of Spain and has an account in Liechtenstein, his/her account will be reported to Spanish authorities by the authorities of Liechtenstein.
  2. If a citizen of the United Kingdom is a tax resident of Spain and has an account in the United Kingdom, his/her account will be reported to Spanish authorities by the authorities of the United Kingdom.
  3. If a citizen of the United Kingdom is a tax resident of Spain and has an account in Serbia, his/her account will not be reported to Spanish authorities because Serbia didn't sign the convention.
  4. If a citizen of the United Kingdom is a tax resident of Serbia and has an account in Liechtenstein, his/her account will be reported to Serbian authorities by the authorities of Liechtenstein because Serbia didn't sign the convention.

Entity Accounts

An entity account is a reportable account if:

A passive NFE is a non-financial entity if more than 50% of its gross income for the precessing calendar year is a passive income or if more than 50% of its assets produce or are held for production of passive income.

Preexisting financial accounts held by reportable entities will not be reported if the aggregate account balance or value doesn't exceed USD 250,000 as of December 31 of a reportable year. However, the account will become reportable if the account balance exceed USD 250,000 as of December 31 of any subsequent calendar year.

New financial accounts held by reportable entities will be reported undependently of the account balance.

For example:

If a citizen of the United Kingdom is a tax resident of Spain and owns a company (a passive NFE) in Bermuda with a corporate account in Luxembourg, the information about this account will be reported to Spanish authorities by the authorities of Luxembourg.

Information To Be Reported

For each of reportable accounts the following information will be reported:

  1. Account holders details: for each of the reportable account holders, the following details will be reported:
    • name;
    • address;
    • jurisdiction(s) of residence;
    • taxpayer identification number (TIN);
    • if a reportable account holder is an individual, date and place of birth;
    • if a reportable account holder is an entity, for each of the controlling person the account holder details listed above are reported.
  2. Account details: account number or its equivalent in the case of absence an account number.
  3. Financial institution details: name and identifying number (if available).
  4. Financial information:
    • account balance;
    • sales proceeds from financial assets;
    • all types of investment income (including interest, dividends, income from certain insurance contracts and other similar types of income);
    • currency in which each amount is denominated.

Start of Information Exchange

According to the Common Reporting Standard the information is to be exchanged starting from the years specified in a jurisdiction's commitment within 9 months after the end of the calendar year to which the information relates.

This means that

If one jurisdiction committed to start the exchange in September 2017 and another in September 2018, the exchange between this pair of jurisdictions will start in September 2018 and only the accounts exisitng in 2017 and the following years will be reported.

The information will only by exchanged with respect to a calendar year between a pair of jurisdiction if both of the conditions below are fulfilled:

Status of Automatic Information Exchange

The table below shows the list of jurisdictions which have signed the convention, their commitments to start the information exchange and the number of signed bilateral agreements to send and receive the information. For countries and territories covered at this website the list of bilateral agreements is available when clicking on the country/territory name.

Country Sign Date Exchange Start Date Bilateral Agreements
AD Andorra 02 November 2016 September 2018 29 send / 29 receive
AI Anguilla 29 October 2014 September 2017 0 send / 38 receive
AG Antigua and Barbuda 29 October 2015 September 2018 0 send / 0 receive
AR Argentina 29 October 2014 September 2017 52 send / 52 receive
AW Aruba 29 October 2014 September 2018 0 send / 0 receive
AU Australia 29 October 2015 September 2018 52 send / 52 receive
AT Austria 29 October 2014 September 2018 50 send / 50 receive
AZ Azerbaijan not signed September 2018 0 send / 0 receive
BH Bahrain not signed September 2018 0 send / 0 receive
BB Barbados 29 October 2015 September 2018 0 send / 0 receive
BE Belgium 29 October 2014 September 2017 58 send / 58 receive
BZ Belize 29 October 2015 September 2018 0 send / 45 receive
BM Bermuda 29 October 2014 September 2017 0 send / 49 receive
BR Brazil 02 November 2016 September 2018 45 send / 45 receive
VG British Virgin Islands 29 October 2014 September 2017 0 send / 48 receive
BN Brunei Darussalam not signed September 2018 0 send / 0 receive
BG Bulgaria 29 October 2015 September 2017 58 send / 58 receive
CA Canada 29 October 2015 September 2018 50 send / 50 receive
KY Cayman Islands 29 October 2014 September 2017 0 send / 49 receive
CL Chile 29 October 2015 September 2018 0 send / 0 receive
CN China not signed September 2018 47 send / 47 receive
CO Colombia 29 October 2014 September 2017 50 send / 50 receive
CK Cook Islands 29 October 2015 September 2018 0 send / 0 receive
CR Costa Rica 29 October 2015 September 2018 0 send / 45 receive
HR Croatia 29 October 2014 September 2017 54 send / 54 receive
CW Curacao not signed September 2018 0 send / 0 receive
CY Cyprus 29 October 2014 September 2017 57 send / 57 receive
CZ Czech Republic 29 October 2014 September 2017 57 send / 57 receive
DK Denmark 29 October 2014 September 2017 58 send / 58 receive
DM Dominica not signed September 2018 0 send / 0 receive
EE Estonia 29 October 2014 September 2017 58 send / 58 receive
FO Faroe Islands 29 October 2014 September 2017 52 send / 52 receive
FI Finland 29 October 2014 September 2017 57 send / 57 receive
FR France 29 October 2014 September 2017 57 send / 57 receive
DE Germany 29 October 2014 September 2017 57 send / 57 receive
GH Ghana 29 October 2015 September 2018 0 send / 0 receive
GI Gibraltar 29 October 2014 September 2017 55 send / 55 receive
GR Greece 29 October 2014 September 2017 58 send / 58 receive
GL Greenland 02 November 2016 September 2018 49 send / 49 receive
GD Grenada 29 October 2015 September 2018 0 send / 0 receive
GG Guernsey 29 October 2014 September 2017 51 send / 51 receive
HK Hong Kong not signed September 2018 0 send / 0 receive
HU Hungary 29 October 2014 September 2017 56 send / 56 receive
IS Iceland 29 October 2014 September 2017 54 send / 54 receive
IN India 29 October 2015 September 2017 53 send / 53 receive
ID Indonesia 29 October 2015 September 2018 0 send / 46 receive
IE Ireland 29 October 2014 September 2017 58 send / 58 receive
IM Isle of Man 29 October 2014 September 2017 50 send / 50 receive
IL Israel 02 November 2016 September 2018 0 send / 0 receive
IT Italy 29 October 2014 September 2017 58 send / 58 receive
JP Japan 29 October 2015 September 2018 51 send / 51 receive
JE Jersey 29 October 2014 September 2017 51 send / 51 receive
KR Korea, Republic of not signed September 2017 53 send / 53 receive
KW Kuwait 02 November 2016 September 2018 0 send / 0 receive
LV Latvia 29 October 2014 September 2017 58 send / 58 receive
LB Lebanon not signed September 2018 0 send / 0 receive
LI Liechtenstein 29 October 2014 September 2017 51 send / 51 receive
LT Lithuania 29 October 2014 September 2017 56 send / 56 receive
LU Luxembourg 29 October 2014 September 2017 58 send / 58 receive
MO Macau not signed September 2018 0 send / 0 receive
MY Malaysia 02 November 2016 September 2018 47 send / 47 receive
MT Malta 29 October 2014 September 2017 58 send / 58 receive
MH Marshall Islands 29 October 2015 September 2018 0 send / 0 receive
MU Mauritius 29 October 2014 September 2018 49 send / 49 receive
MX Mexico 29 October 2014 September 2017 53 send / 53 receive
MC Monaco 02 November 2016 September 2018 46 send / 46 receive
MS Montserrat 29 October 2014 September 2017 0 send / 44 receive
NR Nauru 02 November 2016 September 2018 0 send / 0 receive
NL Netherlands 29 October 2014 September 2017 57 send / 57 receive
NZ New Zealand 29 October 2015 September 2018 50 send / 50 receive
NU Niue 29 October 2015 September 2018 0 send / 0 receive
NO Norway 29 October 2014 September 2017 54 send / 54 receive
PK Pakistan not signed September 2018 0 send / 0 receive
PA Panama not signed September 2018 0 send / 0 receive
PL Poland 29 October 2014 September 2017 57 send / 57 receive
PT Portugal 29 October 2014 September 2017 58 send / 58 receive
QA Qatar not signed September 2018 0 send / 0 receive
RO Romania 29 October 2014 September 2017 55 send / 55 receive
RU Russian Federation 02 November 2016 September 2018 0 send / 0 receive
KN Saint Kitts and Nevis 02 November 2016 September 2018 0 send / 0 receive
LC Saint Lucia 29 October 2015 September 2018 0 send / 37 receive
VC Saint Vincent and The Grenadines 29 October 2015 September 2018 0 send / 44 receive
WS Samoa 29 October 2015 September 2018 0 send / 44 receive
SM San Marino 29 October 2014 September 2017 49 send / 49 receive
SA Saudi Arabia 02 November 2016 September 2018 0 send / 0 receive
SC Seychelles 29 October 2015 September 2017 40 send / 40 receive
SG Singapore not signed September 2018 34 send / 34 receive
SX Sint Maarten (Dutch part) not signed September 2018 0 send / 0 receive
SK Slovakia not signed September 2017 58 send / 58 receive
SI Slovenia 29 October 2014 September 2017 57 send / 57 receive
ZA South Africa 29 October 2014 September 2017 52 send / 52 receive
ES Spain 29 October 2014 September 2017 58 send / 58 receive
SE Sweden 29 October 2014 September 2017 56 send / 56 receive
CH Switzerland 29 October 2015 September 2018 39 send / 39 receive
BS Bahamas not signed September 2018 0 send / 0 receive
TT Trinidad and Tobago not signed September 2018 0 send / 0 receive
TR Turkey not signed September 2018 0 send / 0 receive
TC Turks and Caicos Islands 29 October 2014 September 2017 0 send / 46 receive
AE United Arab Emirates not signed September 2018 0 send / 0 receive
GB United Kingdom 29 October 2014 September 2017 49 send / 49 receive
UY Uruguay 02 November 2016 September 2018 45 send / 45 receive
VU Vanuatu not signed September 2018 0 send / 0 receive

See Also

External Links

  1. Major new steps to boost international cooperation against tax evasion, OECD (external ref)
  2. Standard for Automatic Exchange of Financial Account Information, OECD (external ref)