1. Monitoring the implementation of the AEOI Standard

Abstract

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.

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
1. Albania 1^,5	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. Azerbaijan 1	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	0 7
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. Ecuador 1	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. Ghana 1	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	41 8
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. Jamaica 1	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. Kazakhstan 3	2021	N/A	N/A	N/A	39	57
59. Kenya 1	2022	N/A	N/A	N/A	N/A	- 6
60. Korea	2017	59	67	70	74	76
61. Kuwait 2	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. Maldives 1	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. Nauru 4	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. Nigeria 1	2020	N/A	N/A	25	63	73
80. Niue 4	2018	No RFIs	No RFIs	No RFIs	No RFIs	No RFIs
81. Norway	2017	64	68	71	75	77
82. Oman 2	2020	N/A	N/A	28	28	39
83. Pakistan 1	2018	40	55	57	61	55
84. Panama	2018	32	62	63	67	68
85. Peru 1	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
Year of commitment to first exchanges	Jurisdiction
2023	Jordan 2, Moldova 1, Montenegro 2, Thailand 2, Uganda 1, Ukraine 1
2024	Georgia 1, Rwanda 1, Tunisia 1
2025	Morocco 1
← 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

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