This Alert provides an indicative time table recording the key milestones in the Organisation for Economic Co-operation and Development's Automatic Exchange of Information framework agreed upon by the Early Adopters Group (which includes India, the United Kingdom, Isle of Man, Guernsey, Jersey, Netherlands, Cayman Islands and Belgium, among others). Automatic exchange of information protects the integrity of tax systems.

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What Likely Needs to Happen Between Now and the Milestone Dates?

  • Process of review and monitoring of pre-existing accounts: The financial information to be reported with respect to reportable accounts includes all types of investment income (interest, dividends, income from certain insurance contracts and other similar types of income), as well as account balances and sales proceeds from financial assets.
  • Financial institutions under obligations to report: The financial institutions that are required to report under this framework include not only banks and custodians but also other financial institutions, such as brokers, certain collective investment vehicles and certain insurance companies.
  • Reportable Account Identification: Reportable accounts include accounts held by individuals and entities (which includes trusts and foundations), and the standard includes a requirement for look-through passive entities to report on the individuals that ultimately control these entities.