About the Global Forum
The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) provides a multilateral framework to tackle offshore tax evasion. It brings together 172 jurisdictions dedicated to improving transparency and cooperation for tax purposes.
The Global Forum promotes and assesses the effective implementation of international standards in exchange of information for tax purposes. These consist of the standard on transparency and exchange of information on request (EOIR standard), the automatic exchange of financial account information (the Common Reporting Standard, or CRS) and the automatic exchange of information on crypto-assets (the Crypto-Asset Reporting Framework, or CARF). These standards provide for co-operation among tax authorities worldwide so that they can obtain information necessary to ensure tax compliance.
About the standard on Transparency and Exchange of Information on Request
The EOIR standard is primarily reflected in the 2002 OECD Model Agreement on Exchange of Information on Tax Matters and its commentary, Article 26 of the OECD Model Tax Convention on Income and on Capital and its commentary, and Article 26 of the United Nations Model Double Taxation Convention between Developed and Developing Countries and its commentary.
The EOIR standard provides for the exchange on request of information that is foreseeably relevant for carrying out the provisions of the applicable exchange of information instrument or to the administration or enforcement of the domestic tax laws of a requesting jurisdiction. All 172 Global Forum members, as well as 3 non-members that are relevant to the Global Forum’s work, are assessed on their implementation of the EOIR standard in accordance with the Terms of Reference, which divide the standard into 10 essential elements under three categories: (A) availability of ownership, accounting and banking information, (B) access to information by the competent authority, and (C) exchange of information.
About the EOIR peer review process
The implementation of the EOIR standard has been overseen by the Global Forum through a dedicated and intensive peer review process. The assessments result in recommendations for improvements where appropriate and an overall rating of the jurisdiction’s compliance with the EOIR standard based on:
1. The implementation of the EOIR standard in the jurisdiction’s legal and regulatory framework, with each of the elements of the standard determined to be either (i) in place, (ii) in place but certain aspects need improvement, or (iii) not in place.
2. The implementation of that framework in practice by the jurisdiction with each element being rated (i) compliant, (ii) largely compliant, (iii) partially compliant, or (iv) non-compliant.
Reviewed jurisdictions are expected to address any recommendations made, and progress is monitored by the Global Forum.
The first round of EOIR peer reviews was conducted from 2010 to 2016 under the 2010 Terms of Reference. In 2016, the second round of EOIR peer reviews commenced under the enhanced 2016 Terms of Reference, that notably include additional requirements in relation to availability of and access to beneficial ownership information. The second round of EOIR peer reviews has already covered more than 150 Global Forum members and relevant non-member jurisdictions and is ongoing. Throughout the two rounds of reviews (until 2023), the actions taken by the reviewed jurisdictions to address the recommendations were monitored through an annual follow-up process whereby jurisdictions reported on the progress they had made to address the issued recommendations. In 2021, this process was expanded to include peer input by the Global Forum members, which was analysed by the Secretariat of the Global Forum and issues were brought to the attention of the Peer Review Group (PRG). Where material issues with implications for the implementation of the EOIR standard were identified, additional recommendations could be issued. The peer review and follow-up processes have promoted greater transparency and access to relevant information for tax purposes as jurisdictions have worked to improve their legal and regulatory frameworks supporting EOIR (including by removing bank secrecy for EOI purposes) as well as the implementation of EOIR in practice. This has led to EOIR becoming the core form of international tax cooperation with respect to tackling tax evasion and avoidance with many thousands of requests being made each year. This has also been supported by several jurisdictions benefitting from technical assistance provided by the Global Forum to implement the standard and to make effective use of EOIR.
Given the maturity of the implementation of the EOIR standard, the Global Forum agreed that there might not be a need for a dedicated third round of EOIR peer reviews covering the entire membership of the Global Forum and relevant non-member jurisdictions. Hence, in 2023 the Global Forum decided to move to an enhanced monitoring process to continue to oversee the implementation of the EOIR standard, including to monitor and publish information on the progress made by jurisdictions to implement the standard. More detailed in-depth reviews would then only be conducted in a targeted manner, where warranted.
About the enhanced monitoring process
The Global Forum decided to apply the enhanced monitoring process to the EOIR standard from January 2025 to jurisdictions that have completed their second round of EOIR peer reviews. Accordingly, the PRG, which had overseen the peer review process for the EOIR standard, was transformed into the Peer Review and Monitoring Group for EOIR (PRMG) to reflect its new functions under the enhanced monitoring process.
The enhanced monitoring process builds upon and replaces the prior annual follow-up process. In addition to jurisdictions reporting on their progress to address the issued recommendations and Global Forum members providing peer input, the Secretariat prepares a report on each jurisdiction covered by the process with an analysis of the information received from the jurisdiction and its peers. Under the process, the status of recommendations may be determined reflecting the extent to which they have been addressed and new recommendations may be issued. Ultimately the reports are approved by the PRMG and adopted by the Global Forum Plenary for publication. This process provides for a strengthened approach to follow-up, as well as for more frequent monitoring and transparency than a third round of peer reviews would deliver, to help ensure that the EOIR standard continues to be effectively implemented by all jurisdictions.
A feature of the enhanced monitoring process is the involvement of an assessment panel of 11 experts from various Global Forum members that supports the work of the PRMG in specific circumstances. Where the process results in substantive consequences for a jurisdiction (like issuing a new recommendation where a significant issue is identified, downgrading a rating where the jurisdiction persistently fails to make progress to address its recommendations, or launching an in-depth review of a jurisdiction) the assessment panel is asked to consider such matters and provide its views to the PRMG. The assessment panel also provides its views on decisions to permit a jurisdiction to stop reporting on recommendations previously issued.
The jurisdiction reports indicate a status on the progress made to address every recommendation. In some cases, where a lack of material progress being made to address a recommendation over a considerable length of time is noted, there will be closer monitoring of such a recommendation and a requirement for the jurisdiction to provide more frequent updates. In such cases, this is reflected in the jurisdiction’s report.
The enhanced monitoring process is intended to record the progress made by jurisdictions but is not, aside from in one circumstance, designed to make changes to the ratings issued in the peer review. In this regard, any upgrade of ratings can only be done through an in-depth review. The circumstance in which a rating may be downgraded through the enhanced monitoring process is, where there remains a persistent lack of progress to address a recommendation even after there has been a closer monitoring of the situation.
For more information on the enhanced monitoring process, refer to Part II of the Handbook for Second Round Peer Reviews and New Monitoring Processes on Transparency and Exchange of Information on Request.1
About the Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025
This report under the Global Forum’s enhanced monitoring process for 2025 reflects the progress in the implementation of the EOIR standard by 25 out of the 82 jurisdictions covered under the first cycle of the first round of enhanced monitoring.
The report has two parts:
Part I provides general information and comprises the following two chapters:
Chapter 1 explains the scope of coverage of this monitoring report (the standard, jurisdictions and recommendations covered by the report). It also presents the methodology followed for the enhanced monitoring process.
Chapter 2 presents a summary of the findings and aggregate outcomes of the enhanced monitoring process for 2025.
Part II provides jurisdiction-specific information addressing the individual jurisdiction reports and comprises the following two chapters:
Chapter 3 of the report contains guidance to understand the structure of the individual jurisdiction reports.
Chapter 4 contains the 25 individual jurisdiction reports, arranged in alphabetical order.2
For more information on the work of the Global Forum, visit the Global Forum’s website.