The amazing development of exchange of information in tax matters: from double tax treaties to FATCA and the CRS

Abstract

This article provides an overview of the development of international tax and financial reporting, and examines modern approaches to compelling the disclosure of offshore financial accounts, comparing tax information exchange agreements to the comprehensive bilateral reporting agreements of the USA under the Foreign Account Tax Compliance Act (FATCA), and to the recently released OECD Common Reporting Standard (CRS). Beginning with FATCA, and expanding through the CRS and bilateral automatic reporting treaties, the trend is towards ever more transparency.