Published 03 November 2014
Last updated 21 November 2016
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 2016, 36 jurisdictions more joined the multilateral agreement, making 87 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.
To clarify the information flows, consider the examples:
By the end of 2018 101 jurisdictions will exchange the information on financial accounts.
Several notes should be made about status of commitments of the European countries and territories:
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 operating in a jurisdiction that joined the convention, will report in this jurisdiction.
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.
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.
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.
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.
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.
For each of reportable accounts the following information will be reported:
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:
The table below shows the list of jurisdictions and their commitments to start the information exchange.
|Country||Sign Date||Exchange Start Date|
|Albania||29 October 2014||September 2018|
|Andorra||not signed||September 2018|
|Anguilla||29 October 2014||September 2017|
|Antigua and Barbuda||29 October 2015||September 2018|
|Argentina||29 October 2014||September 2017|
|Aruba||29 October 2014||September 2018|
|Australia||29 October 2015||September 2018|
|Austria||29 October 2014||September 2018|
|Bahrain||not signed||September 2018|
|Barbados||29 October 2015||September 2017|
|Belgium||29 October 2014||September 2017|
|Belize||29 October 2015||September 2018|
|Bermuda||29 October 2014||September 2017|
|Brazil||not signed||September 2018|
|British Virgin Islands||29 October 2014||September 2017|
|Brunei Darussalam||not signed||September 2018|
|Bulgaria||29 October 2015||September 2017|
|Canada||29 October 2015||September 2018|
|Cayman Islands||29 October 2014||September 2017|
|Chile||29 October 2015||September 2018|
|China||not signed||September 2018|
|Colombia||29 October 2014||September 2017|
|Cook Islands||29 October 2015||September 2018|
|Costa Rica||29 October 2015||September 2018|
|Croatia||29 October 2014||September 2017|
|Curacao||not signed||September 2017|
|Cyprus||29 October 2014||September 2017|
|Czech Republic||29 October 2014||September 2017|
|Denmark||29 October 2014||September 2017|
|Dominica||not signed||September 2018|
|Estonia||29 October 2014||September 2017|
|Faroe Islands||29 October 2014||September 2017|
|Finland||29 October 2014||September 2017|
|France||29 October 2014||September 2017|
|Germany||29 October 2014||September 2017|
|Ghana||29 October 2015||September 2018|
|Gibraltar||29 October 2014||September 2017|
|Greece||29 October 2014||September 2017|
|Greenland||not signed||September 2017|
|Grenada||29 October 2015||September 2018|
|Guernsey||29 October 2014||September 2017|
|Hong Kong||not signed||September 2018|
|Hungary||29 October 2014||September 2017|
|Iceland||29 October 2014||September 2017|
|India||29 October 2015||September 2017|
|Indonesia||29 October 2015||September 2018|
|Ireland||29 October 2014||September 2017|
|Isle of Man||29 October 2014||September 2017|
|Israel||not signed||September 2018|
|Italy||29 October 2014||September 2017|
|Japan||29 October 2015||September 2018|
|Jersey||29 October 2014||September 2017|
|Korea, Republic of||not signed||September 2017|
|Kuwait||not signed||September 2018|
|Latvia||29 October 2014||September 2017|
|Lebanon||not signed||September 2018|
|Liechtenstein||29 October 2014||September 2017|
|Lithuania||29 October 2014||September 2017|
|Luxembourg||29 October 2014||September 2017|
|Macau||not signed||September 2018|
|Malaysia||not signed||September 2018|
|Malta||29 October 2014||September 2017|
|Marshall Islands||29 October 2015||September 2018|
|Mauritius||29 October 2014||September 2018|
|Mexico||29 October 2014||September 2017|
|Monaco||not signed||September 2018|
|Montserrat||29 October 2014||September 2017|
|Nauru||not signed||September 2018|
|Netherlands||29 October 2014||September 2017|
|New Zealand||29 October 2015||September 2018|
|Niue||29 October 2015||September 2017|
|Norway||29 October 2014||September 2017|
|Panama||not signed||September 2018|
|Poland||29 October 2014||September 2017|
|Portugal||29 October 2014||September 2017|
|Qatar||not signed||September 2018|
|Romania||29 October 2014||September 2017|
|Russian Federation||not signed||September 2018|
|Saint Kitts and Nevis||not signed||September 2018|
|Saint Lucia||29 October 2015||September 2018|
|Saint Vincent and The Grenadines||29 October 2015||September 2018|
|Samoa||29 October 2015||September 2018|
|San Marino||29 October 2014||September 2017|
|Saudi Arabia||not signed||September 2018|
|Seychelles||29 October 2015||September 2017|
|Singapore||not signed||September 2018|
|Sint Maarten (Dutch part)||not signed||September 2018|
|Slovakia||not signed||September 2017|
|Slovenia||29 October 2014||September 2017|
|South Africa||29 October 2014||September 2017|
|Spain||29 October 2014||September 2017|
|Sweden||29 October 2014||September 2017|
|Switzerland||29 October 2015||September 2018|
|Bahamas||not signed||September 2018|
|Trinidad and Tobago||not signed||September 2017|
|Turkey||not signed||September 2018|
|Turks and Caicos Islands||29 October 2014||September 2017|
|United Arab Emirates||not signed||September 2018|
|United Kingdom||29 October 2014||September 2017|
|Uruguay||not signed||September 2018|
|Vanuatu||not signed||September 2018|