MCAA – Multilateral Competent Authority Agreement

The Multilateral Competent Authority Agreement (MCAA) is the central legal instrument that enables the practical implementation of the Automatic Exchange of Information (AEOI) under the Common Reporting Standard (CRS). It was signed on 29 October 2014 at the OECD's Global Forum in Berlin by 51 jurisdictions.

The MCAA relies on Article 6 of the OECD Convention on Mutual Administrative Assistance in Tax Matters (MAC) and creates the bilateral relationships between signatory jurisdictions required for the automatic exchange of financial information without needing to conclude separate bilateral agreements.

The MCAA was created as the necessary legal foundation for the global rollout of the CRS. After the G20 tasked the OECD in 2013 with developing a global standard for automatic information exchange, the MCAA was designed as an efficient multilateral vehicle that eliminates the need for bilateral negotiations.

• October 2014: Signing of the MCAA by 51 jurisdictions in Berlin
• 2015–2016: Additional jurisdictions accede; activation of bilateral relationships via the OECD portal
• 2017: First data exchanges based on the MCAA between Early Adopters
• 2018 onwards: Continuous accession of further states; today over 120 signatory states
• 2023: Publication of the revised CRS 2.0 by the OECD, covering inter alia crypto-assets and digital financial products
• November 2024: Signing of the CRS MCAA Addendum to integrate the CRS 2.0 amendments into the exchange framework

Complementing the CRS MCAA, the Crypto-Asset Reporting Framework (CARF) along with a dedicated CARF MCAA was adopted in 2023, extending automatic information exchange to crypto-asset transactions.

The Swiss Federal Council approved the signing of the MCAA on 19 November 2014; the formal signature at the OECD took place on 2 December 2014. Switzerland gradually activated bilateral relationships with its key partner states.

The MCAA governs the automatic exchange of information pursuant to the CRS between the tax authorities of signatory states:

• Personal scope: Natural persons and legal entities that are tax resident in one of the contracting states
• Material scope: Financial information pursuant to the CRS (accounts, balances, income, proceeds)
• Activation mechanism: Exchange between two jurisdictions is activated once both have signed the MCAA and declared their intent to engage in mutual exchange
• Confidentiality: All exchanged data is subject to the same protective provisions as those provided in the MAC
• Bilateral exchange relationships: As of 2024, over 5,400 activated bilateral exchange relationships exist under the MCAA
• CRS 2.0 and CARF: From 2026/2027, the scope will be significantly expanded through the CRS 2.0 revision (including digital financial products and crypto-assets) and the complementary Crypto-Asset Reporting Framework (CARF)

• MAC legal basis: Jurisdictions must have ratified the OECD Convention on Mutual Administrative Assistance in Tax Matters (MAC)
• CRS implementation: National legislation must have transposed the CRS into domestic law
• Reciprocity: Exchange is in principle based on reciprocity; a jurisdiction only sends data to countries from which it also receives data
• Activation declaration: Each jurisdiction must notify the OECD Secretariat of its list of partner states with which it wishes to exchange data
• Minimum data protection standards: The receiving authority must demonstrate adequate data protection standards

mcaa (24,22) and beps-a7 (24,28) had only 6 degrees longitude separation at identical latitude. Moved mcaa to lat 26.

3 corrections:
- Second wave data exchange date incorrect
- First CRS data exchange date incorrect
- Official URL returns HTTP 403
3 updates:
- CRS 2.0 amendments and MCAA Addendum missing
- last_amended date unclear and possibly incorrect
- Number of signatory states outdated (115 instead of 120)
3 clarifications.
1 note.