8 January 2015, updated 6 November 2017
On 29 October 2014, 51 jurisdictions (countries and territories) signed a multilateral agreement to automatically exchange information on financial accounts for tax purposes. During the following two years 36 jurisdictions have joined the convention. This is the first ever agreement to exchange this type of information automatically. By the end of 2018, when more jurisdictions join the convention, 102 jurisdictions will exchange the information on financial accounts.
Hence, there still will be more than 100 jurisdictions which will not exchange the information automatically. However, the absence of the automatic information exchange between these jurisdictions does not mean, that there can be no information exchange at all: these jurisdictions can still conduct the exchange in other ways: either on request or spontaneously.
Although almost all European countries and offshore financial centers will participate in the information exchange, there are still several European countries and offshore financial centers which will not exchange the information automatically. Moreover, 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.
The main principles of the information exchange can be summarized as follows:
The information exchange is covered in more details in Automatic Exchange of Information on Financial Accounts
Apart from the automatic exchange, the information may be exchanged in other ways:
The financial accounts information will be exchanged only between the countries and the territories for which the convention is in force and in effect. Hence, if a jurisdiction don't sign the convention, this jurisdiction will neither automatically report the account information, nor automatically receive the account information from the jurisdictions which signed the convention.
Consider the following cases:
In the case 2 from the list above, there will be no information exchange between the jurisdictions. To illustrate this case, consider an example:
Serbia won't exchange the information, while the United Kingdom will. This means that:
It should be noted that absence of the automatic information exchange between a pair of jurisdictions does not mean that there will be no information exchange at all. The information may be exchanged either on request or spontaneously.
Although a lot of European countries made a commitment to start the automatic exchange of information, there are several countries will not exchange the information automatically:
Although the term offshore financial centre is not precisely defined, it usually means a small, low-tax jurisdiction specializing in providing financial services to non-resident legal entities and individuals. Because there is no generally accepted definition of the term, lists of jurisdictions considered as offshore financial centers vary from source to source.
The table below summarizes participation of offshore financial centers as defined by International Monetary Fund (IMF) in the automatic information exchange:
|Country||Participates In Exchange||Exchange Start Date||Bilateral Agreements|
|Andorra||Yes||September 2018||29 send / 29 receive|
|Anguilla||Yes||September 2017||0 send / 38 receive|
|Aruba||Yes||September 2018||0 send / 0 receive|
|Bahamas||Yes||September 2018||0 send / 0 receive|
|Belize||Yes||September 2018||0 send / 45 receive|
|Bermuda||Yes||September 2017||0 send / 49 receive|
|British Virgin Islands||Yes||September 2017||0 send / 48 receive|
|Cayman Islands||Yes||September 2017||0 send / 49 receive|
|Cook Islands||Yes||September 2018||0 send / 0 receive|
|Curacao||Yes||September 2018||0 send / 0 receive|
|Cyprus||Yes||September 2017||57 send / 57 receive|
|Gibraltar||Yes||September 2017||55 send / 55 receive|
|Guernsey||Yes||September 2017||51 send / 51 receive|
|Isle of Man||Yes||September 2017||50 send / 50 receive|
|Jersey||Yes||September 2017||51 send / 51 receive|
|Liechtenstein||Yes||September 2017||51 send / 51 receive|
|Macau||Yes||September 2018||0 send / 0 receive|
|Malaysia||Yes||September 2018||47 send / 47 receive|
|Monaco||Yes||September 2018||46 send / 46 receive|
|Montserrat||Yes||September 2017||0 send / 44 receive|
|Palau||No||0 send / 0 receive|
|Panama||Yes||September 2018||0 send / 0 receive|
|Samoa||Yes||September 2018||0 send / 44 receive|
|Seychelles||Yes||September 2017||40 send / 40 receive|
|Turks and Caicos Islands||Yes||September 2017||0 send / 46 receive|
|Vanuatu||Yes||September 2018||0 send / 0 receive|
The following countries and territories have no bilateral agreements with others to either send or receive the information automatically:
The following countries and territories have no bilateral agreements with others send the information automatically:
The list below shows the jurisdictions which will not automatically exchange information. The United States undertakes automatic information exchanges according to from 2015 and has 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.