In addition to translating the CRS into domestic law, a key element of its successful implementation is the putting in place of an international framework that allows the automatic exchange of CRS information between jurisdictions. For exchanges between EU Member States, the EU has transposed the CRS by virtue of the amended EU Directive on Administrative Cooperation (DAC2).


With over 100 jurisdictions having committed to exchanging information with each other under the CRS, exchange relationships between jurisdictions are typically be based on the multilateral Convention on Mutual Administrative Assistance in Tax Matters (the "Multilateral Convention" - see also Chart of jurisdictions participating in the Multilateral Convention), in which more than 100 jurisdictions are participating, and the CRS Multilateral Competent Authority Agreement (the "CRS MCAA"), which is based on its Article 6. In limited instances, where it is not yet possible to rely on the Multilateral Convention and the CRS MCAA to exchange information, jurisdictions may rely on a bilateral agreement, such as a double tax treaty or a tax information exchange agreement.


The CRS MCAA specifies the details of what information will be exchanged and when. It is a multilateral framework agreement, with the subsequent bilateral exchanges coming into effect between those signatories that file the subsequent notifications under Section 7 of the CRS MCAA.


On 29 October 2014, 51 jurisdictions participated in the first ever signing ceremony for the CRS MCAA in Berlin. The significance of this event was demonstrated by the participation of 38 ministers in the signing ceremony, the largest gathering of ministers to take joint action to address tax evasion. Kuwait joined the Agreement in August 2016, bringing the current total number of signatories to 84.




Exchange relationships under the CRS MCAA

From early 2016, this section will allow you to verify if an effective exchange relationship is in place between two jurisdictions under the MCAA that allows for the automatic exchange of CRS information and when this exchange relationship became effective. 

Based on the timelines to which jurisdictions have committed to implementing the CRS (i.e. 2017 or 2018), it is expected that the first exchange relationships under the MCAA will become effective in late 2016/early 2017.