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More countries commit to tax transparency with international accords

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Several international agreements have been signed in the past week. The UK has signed FATCA-style intergovernmental agreements with Montserrat, the Turks and Caicos Islands and the British Virgin Islands. As well as signing UK FATCA intergovernmental agreements, the Crown dependencies and overseas territories have also agreed to be part of the G5 multilateral automatic tax information exchange standard (which in April 2013, the G5 – the UK, France, Germany, Italy and Spain – committed to developing and piloting: the so-called ‘G5 FATCA’). Of the UK’s ten Crown dependencies and overseas territories, only Anguilla is yet to sign up. As with all these types of bilateral agreements, they will come into force when each party has notified the other in writing that it has completed the necessary internal procedures.

Luxembourg, Liechtenstein, Colombia, Greece, Iceland and Malta are the latest countries to commit to automatic exchange of tax information in the G5 FATCA pilot. A total of 37 countries have now signed up to the project. By way of background, in April 2013, the UK, along with France, Germany, Italy and Spain (the G5), committed to developing and piloting a multilateral, automatic tax information exchange standard. The standard, broadly based on the principles and approach set out in the model 1 agreement used to implement US FATCA between individual countries and the US, is intended to form the basis of a new international standard for the automatic exchange of tax information, which is seen as an essential part of enabling tax administrations around the world to address abusive tax evasion.

Costa Rica and the Cayman Islands have signed intergovernmental agreements (IGAs) with the US under US FATCA. The Costa Rican IGA (signed on 26 November 2013) is based on the reciprocal model 1A agreement. The Cayman Islands IGA (signed on 29 November 2013), based on the non-reciprocal model 1B, was originally initialled on 13 August 2013 pending formal UK governmental approval.

Following the announcement by the US a few months ago of a delay of six months before the commencement of US FATCA, the UK government has announced that this revised timeline will also apply to similar agreements signed with the Crown dependencies and overseas territories. This means that any commitments for UK financial institutions will now commence as of 30 June 2014. Only accounts in existence on or after this date will be subject to reporting, and 2014 will be the first year that the reporting covers.

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