Timeline 2015

The year 2015 is the year of consistent implementation of international tax transparency initiatives:

• CRS/AEOI (2015): Implementation of the OECD Common Reporting Standard advances; around 100 jurisdictions commit to automatic exchange of financial account information (first exchange September 2017)
• BEPS Action Plan (October 2015): The OECD publishes final reports on all 15 BEPS action items, establishing internationally coordinated rules against tax avoidance
• 4th EU Anti-Money Laundering Directive (May 2015): Tightened AML standards in the EU, with mandatory beneficial ownership registers for the first time

The Global Standard for Automatic Exchange of Financial Account Information (CRS) was adopted by the OECD Council in July 2014; the first wave of early-adopter countries began legislative transposition in 2015 (data collection from January 1, 2016) for a first data exchange in September 2017. CRS was designed as a multilateral counterpart to FATCA, using the legal basis of the Multilateral Competent Authority Agreement (MCAA).

In parallel, the OECD published in October 2015 the final reports on all 15 action items of the Base Erosion and Profit Shifting (BEPS) project, launched in 2013 at the initiative of the G20. BEPS addressed gaps and mismatches in international tax rules exploited by multinational corporations to artificially shift profits to low-tax jurisdictions.

The 4th EU Anti-Money Laundering Directive (2015/849/EU) was approved by the European Parliament in May 2015 and published in the Official Journal in June 2015; it had to be transposed into national law by June 2017. It introduced mandatory national registers for beneficial owners for the first time.

Areas affected in 2015:

• CRS: All financial institutions (banks, brokers, funds, insurers) in over 100 participating countries
• BEPS: Multinational corporations, international tax treaties, transfer pricing rules
• 4th AMLD: All financial institutions and certain non-financial businesses in the EU

• CRS: Annual reporting of account holder data (name, address, tax identification number, account balance, capital income) to home authority
• BEPS AP 13: Country-by-Country Reporting for multinational groups with revenue over EUR 750 million
• BEPS AP 5: Minimum standard for harmful tax practices (nexus approach for IP regimes)
• 4th AMLD: Beneficial ownership register, risk-based AML approach, PEP screening

2 corrections:
- CRS 'enters into force' September 2015 is misleading
- 4th AMLD: Adoption date of May 20, 2015 (European Parliament) is incomplete; Council formal adoption was June 25, 2015
4 clarifications.
3 notes.