Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025

Bermuda

Bermuda joined the Global Forum in 2009. Bermuda underwent its Second Round of EOIR Peer Review in 2017 (Bermuda’s 2017 Report),1 which assessed its legal and regulatory framework in force as at 29 May 2017 and its practical implementation, including in respect of EOI requests received and sent during the review period from 1 April 2013 to 31 March 2016. Bermuda received an overall rating of Largely Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.b.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	LC
Ratings	PC	LC	C	C	C	C	C	LC	C	C

Status of implementation of recommendations issued in the peer review report

Bermuda received eight in-box recommendations in relation to Elements A.1, A.2, A.3 and C.3.

This monitoring report assesses the actions taken by Bermuda to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that six recommendations are “in the process of being addressed” and that two recommendations are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”. The recommendation pertaining to Element A.1 that is “considered provisionally addressed in the context of the monitoring process, subject to detailed validation” gave rise to a new recommendation to monitor the implementation of changes to the legal framework. In addition, two new recommendations are issued to Bermuda under Element C.5 on timeliness of responses and provision of status updates. The report advises on actions required.

Element A.1: Availability of ownership and identity information

1. Definition of beneficial ownership and availability of beneficial ownership information for all companies and partnerships

 

Recommendation (A.1, framework)	Bermuda should ensure that beneficial ownership information is available for all relevant entities.
Underlying factor	The Bermuda Monetary Authority collects information on “ultimate beneficial owners” of relevant legal entities in many instances as part of its role as exchange controller. However, this information may not always mirror the definition of beneficial owner under the international standard and may not identify a natural person who exercises ultimate effective control over the legal entity. Moreover, beneficial ownership information, as defined under the standard, is required to be collected by AML obligated persons, such as financial institutions, lawyers, accountants, trust companies and licensed corporate service providers, as part of their customer due diligence obligations. However, there is no legal requirement for companies and partnerships to engage an AML obligated person in Bermuda, although in practice most of them are likely to do so. (see paragraphs 65, 94 et seq., 109 to 113 and 146 of the Bermuda’s 2017 Report for more information)
Summary of actions reported	Alongside the existing AML and exchange control regimes, since 2018, Bermuda has put in place a beneficial ownership regime which obliges all relevant entities to keep a register of beneficial ownership information and file such information with the central register. The definition and method of identification of beneficial owners have been amended in the Companies Act, the Limited Liability Company Act and the Partnership Act to a cascading approach to capture (i) individuals who directly or indirectly own or control more than 25% of the shares, voting rights or interests in a company or partnership, (ii) if no such individual or individuals referred to in point (i) exist or can be identified, individuals who control a company or partnership by other means, or (iii) individuals who hold the position of senior manager, if no other natural person can be identified as beneficial owner. New reforms are under consultation and would include changing to a simultaneous approach of identifying beneficial owners, consolidating the beneficial ownership regime under a single act and transferring oversight of the central register from the Monetary Authority to the Company Registrar.
Conclusion	Bermuda has made progress to address the recommendation through reforms enacted in 2018. All relevant entities must maintain up-to-date beneficial ownership information and report such information to a central register. The new definition of beneficial owner and method of identification are not fully in line with the standard. First, the second step of identifying individuals that control an entity by means other than ownership applies if no individual exists or can be identified under the first step but does not apply in case of doubt about the individual(s) identified under step one, which is required under the standard. Second, the identification of beneficial owners of partnerships is limited to a 25% threshold, as for companies. This means that not all parties to the partnership and any natural person(s) who exercise control over the partnership might be identified in line with the standard. Other planned changes to the legal framework are yet to be put in place. Bermuda should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Bermuda should – Report on the implementation and monitoring of the 2018 legal changes. Provide information on the new legislative changes and their implementation as pertains to the definition of beneficial ownership, the legal framework and the oversight of the central register.

2. Availability of beneficial ownership information for trusts

 

Recommendation (A.1, framework)	Bermuda should take all reasonable measures to ensure that beneficial ownership information is available to their competent authorities in respect of trusts governed by the laws of Bermuda or in respect of which a trustee is resident in Bermuda.
Underlying factor	In respect of exempted (non-licensed) trustees, such as private trust companies, the statutory requirements to identify beneficiaries appear to be limited to the immediate beneficiaries. Also, there are no statutory requirements to identify a protector of the trust (if any) and any other natural person exercising ultimate effective control over the trust. (see paragraphs 164 to 168 of the Bermuda’s 2017 Report for more information)
Summary of actions reported	Bermuda enacted legislative changes in 2018 as pertaining to information about trusts. First, all private trust companies that do not have a relationship with an AML-obliged person must register as non-licensed financial institutions under the Proceeds of Crime Act 2008 and are subject to AML obligations and oversight. The Monetary Authority has identified no issues during a reconciliation exercise that aimed at checking whether all private trust companies are subject to AML oversight, either through a service provider or through registration. Second, the definition of beneficial ownership of legal arrangements in the context of financial institutions’ customer due diligence, applicable to registered private trust companies, was amended to include any individual who is entitled to a specified interest in the trust property, the class of persons in whose main interest the trust is set up or operates, any individual who has control over the trust, and the settlor of the trust. General and sector-specific AML guidance notes take a broad approach to the meaning of control and specifically refer to the protector. Third, the amended Trustee Act 1975 requires non-professional trustees in Bermuda to keep accurate, adequate and up-to-date identity information on settlors, protectors, beneficiaries and any other natural person exercising ultimate effective control over the trust. The look-through approach is established practice in Bermuda.
Conclusion	Bermuda appears to have taken appropriate action to address the recommendation. Private trust companies without relationship with an AML-obliged person must register with the Monetary Authority and non-professional trustees now have beneficial ownership record keeping obligations. The definitions of beneficial ownership for non-professional trustees, private trust companies, corporate service providers and licensed trust businesses have been expanded to include any natural person with control over the trust. No explicit guidance is available on how to look through legal entities or arrangements when they participate in a trust and on how to identify the individuals that ultimately exercise effective control over them, but Bermuda confirmed that the reference to individuals and trust structures in the general guidance notes assumes a look-through approach and that the look-through approach is common practice. The implementation and enforcement in practice of these legislative amendments is yet to be ascertained. Therefore, Bermuda is expected to report progress on the implementation of the changes in the legal and regulatory framework under a new recommendation. Bermuda is recommended to monitor the implementation of the 2018 legal changes on requirements to identify beneficial owners of trusts in order to ensure the availability of accurate, adequate and up-to-date beneficial ownership information in line with the standard.
Status determined	Existing recommendation: Considered provisionally addressed in the context of the monitoring process, subject to detailed validation New recommendation issued.
Actions required	Existing recommendation: No immediate action required. New recommendation: In its next self-assessment in 2028, Bermuda should – Report on the implementation of requirements to identify beneficial owners of trusts for exempted (non-licensed) trustees, including through monitoring and enforcement actions and demonstrating the consistent application of the look-through approach where required.

3. Use of monitoring and enforcement powers to ensure availability of legal ownership and identity information

 

Recommendation (A.1, practice)	Bermuda should ensure that all its monitoring and enforcement powers are appropriately exercised in practice to support the legal requirements which ensure the availability of ownership and identity information in all cases.
Underlying factor	During the review period, the Registrar did not exercise his monitoring and enforcement powers to support the legal requirements for the availability of ownership and identity information with regard to companies and partnerships. Since then, the Registrar of Companies (Compliance Measures) Act 2017 came into force in March 2017. This Act empowers the Registrar of Companies to monitor and regulate registered entities through inspections and enforcement. The Registrar established a new compliance unit and commenced to exercise its statutory powers. (see paragraphs 78 to 81 of the Bermuda’s 2017 Report for more information)
Summary of actions reported	The Registrar undertakes Annual Corporate Governance Monitoring to ask entities about their compliance with various obligations, including with regards to the availability of legal ownership and identity information. In 2023, 1 357 entities representing 8% of the total (including a proportional share of companies, limited liability companies and partnerships) underwent desk-based review in form of a questionnaire. The initial compliance rate was 95%. In 2024, 789 entities, or 4.6% of the total number of entities on the register at that time, were selected for desk-based review. The initial compliance rate was 88%, with further reviews ongoing. The Exchange Controller oversees the compliance of companies subject to exchange control regulations with legal ownership filing obligations through a compliance programme composed of checks before transactions and monthly sample reviews.
Conclusion	Bermuda has made progress to address the recommendation. Companies, limited liability companies and partnerships are subject to ongoing desk-based monitoring and compliance rates are high. On-site inspections are yet to cover legal ownership and identity information. Little information is available on how entities are selected for desk-based reviews, including whether risk factors are considered. It appears that no checks are performed on companies that submit the questionnaire on whether they actually maintain ownership information. Bermuda should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Bermuda should – Report further on monitoring and enforcement actions taken to ensure the compliance of entities with their legal ownership and identification, record keeping and filing obligations, including information on selection criteria, on-site inspections and supported by relevant statistics.

4. Monitoring and enforcement of compliance by entities and AML-obliged persons with beneficial ownership identification and updating obligations

 

Recommendation (A.1, practice)	Bermuda should enhance the monitoring and enforcement of the compliance with the obligations to update beneficial ownership information. This includes establishing adequate oversight of corporate service providers and ensure that they perform adequate customer due diligence and maintain beneficial ownership information of their customers in practice.
Underlying factor	Bermuda has a comprehensive system requiring that information on “ultimate beneficial owners” of relevant legal entities and arrangements be available in the hands of the exchange controller and that beneficial ownership information, as defined under the standard, be available in the hands of AML obligated persons. However, (i) there is limited oversight and enforcement of the compliance with the obligations to update “ultimate beneficial ownership” information pursuant to the exchange control regulations; and (ii) the supervision of CSPs’ [corporate service providers’] compliance with their customer due diligence obligations and identify the beneficial owner under the AML framework is yet to be implemented. (see paragraphs 106 and 118 to 127 of the Bermuda’s 2017 Report for more information)
Summary of actions reported	Since 2018, corporate service providers are subject to risk-based AML supervision, including on their beneficial ownership updating obligations. The initial on-site supervision included the five largest corporate service providers with around 70% of market share. Within the first years, the highest risk entities were subject to on-site inspections, representing 85% of total client volume and enforcement action was taken where applicable. In 2023 to 2025, the oversight continued, with on-site inspections focusing on smaller and lower-risk entities. Three full-scope AML on-site inspections were conducted in 2023 and seven in 2024. The compliance rate in 2023 was 47% and 77% in 2024. Follow-up supervision ensures that all deficiencies are addressed, by presenting the inspection findings to the entity and requesting a remediation plan to be approved by the Monetary Authority. Over the past two years, one enforcement action was taken. As part of its Annual Corporate Governance Monitoring, the Registrar monitors entities’ compliance with obligations to identify beneficial owners, keep beneficial ownership registers and provide filings and updates to the central register. In 2023, 1 357 entities or 8% of the total (including a proportional share of companies, limited liability companies and partnerships) underwent desk-based review in form of a questionnaire. Out of that sample, 7.7% of entities were subject to on-site inspections as they had not provided answers to the questionnaire within the required timeframe or had not satisfactorily answered follow-up questions. The initial compliance rate was 95%. In 2023, four entities were found to be non-compliant with beneficial ownership information updating and verification obligations and were issued civil penalties. One entity had paid the fine at the time of drafting of this report. In 2024, 789 entities, or 4.6% of the total number of entities on the register at that time, were selected for desk-based review. 6% of them were subject to on-site inspections. The initial compliance rate was 88%. To date, no cases of non-compliance have been detected. In 2023 and 2024, the Exchange Controller selected 210 companies for a compliance programme with regards to the exchange control regulations, with more than half of them becoming subject to remediation measures and warning letters. Some deficiencies were the lack of response to the programme itself while operational failures mainly related to the timeliness of updates provided to the Controller. Most failures were promptly addressed by the companies. A fine was issued to one non-compliant entity, with other entities remediating their issues upon first contact with the Enforcement Department. The exchange control regime has been de-prioritised due to the implementation of the beneficial ownership regime supervised by the company registrar.
Conclusion	Bermuda has made progress to address the recommendation. Monitoring and enforcement actions have been implemented under the corporate services provider licensing regime, the new beneficial ownership register approach and the exchange control regulations. Little information is available on how entities and arrangements are selected for desk-based reviews, including whether risk factors are considered. Information about enforcement action is incomplete. It appears that no checks are performed on companies that submit the questionnaire on whether they actually maintain up-to-date information. Bermuda should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Bermuda should – Report further on monitoring and enforcement actions with regard to beneficial ownership identification and updating obligations under the corporate services provider licensing regime and the beneficial ownership register regime, including information on selection criteria, scope of inspections, deficiencies identified, and enforcement measures applied, and supported by relevant statistics.

Element A.2: Availability of accounting information

5. Use of monitoring and enforcement powers to ensure the availability of accounting information

 

Recommendation (A.2, practice)	Bermuda should ensure that all its appropriate monitoring and enforcement powers are sufficiently exercised in practice to support the legal requirements which ensure the availability of accounting information in all cases.
Underlying factor	Except for those entities that are subject to licensing with the BMA [Bermuda Monetary Authority], no system of monitoring of compliance with accounting record keeping requirements was in place during the review period, which may cause the legal obligations to keep accounting records to be difficult to enforce. Since then, the Registrar of Companies (Compliance Measures) Act 2017 came into force in March 2017. This Act empowers the Registrar of Companies to monitor and regulate registered entities through inspections and enforcement. The Registrar established a new compliance unit and commenced to exercise its statutory powers. (see paragraphs 218 to 221 of the Bermuda’s 2017 Report for more information)
Summary of actions reported	As part of its Annual Corporate Governance Monitoring, the Registrar monitors entities’ compliance with accounting record keeping obligations. In 2023, 1 357 entities representing 8% of the total (including a proportional share of companies, limited liability companies and partnerships) underwent desk-based review in form of a questionnaire. Out of that sample, 7.7% of entities were subject to on-site inspections as they had not provided answers to the questionnaire within the required timeframe or had not satisfactorily answered follow-up questions. The initial compliance rate was 95%. In 2024, 789 entities, or 4.6% of the total number of entities on the register at that time, were selected for desk-based review. 6% of them were subject to on-site inspections. The initial compliance rate was 88%. The ten entities non-compliant in 2023 with accounting record keeping requirements were subject to civil fines, with six having paid so far. Further compliance work is being carried out on 33 entities inspected in 2024.
Conclusion	Bermuda has made progress to address the recommendation. The Registrar has carried out desk-based reviews and on-site inspections of entities’ accounting record keeping practices and imposed penalties in cases of non-compliance. Little information was provided on how entities are selected for desk-based reviews, including whether risk factors are considered, and the depth of the controls performed. Insufficient details are available on the enforcement actions put in place in case of non-compliance. It appears that no checks are performed on entities that submit the questionnaire on whether they actually keep accounting records according to the requirements. Bermuda should report further progress and details in the next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Bermuda should – Report further on the use of monitoring and enforcement powers with regards to entities’ accounting record keeping obligations, including information on selection criteria, scope of inspections, deficiencies identified, and enforcement measures applied, and supported by relevant statistics.

6. Monitoring the implementation of record-keeping obligations on liquidated companies

 

Recommendation (A.2, practice)	Bermuda should monitor the implementation of the recently introduced record keeping obligations regarding liquidated companies to ensure that records are kept for a minimum period of five years in all cases.
Underlying factor	Bermuda’s law in force during the review period provided the court with discretion of determining how long books and records of an involuntarily liquidated company should be maintained following its dissolution and, in practice, the court often determined that such books and records should be destroyed immediately after liquidation. This has prevented Bermuda from replying to one EOI request during the review period. Effective as of 10 March 2017, Bermuda’s law requires that the liquidator maintain records of account for five years from the end of the period to which such records of account relate. (see paragraphs 205 to 207 of the Bermuda’s 2017 Report for more information)
Summary of actions reported	In 2023, the Registrar desk reviewed a sample of liquidators appointed to 280 entities dissolved within the prior 5 calendar years, finding a 100% compliance rate with accounting record keeping obligations. In 2024, liquidators of 54 entities dissolved during 2023 were subject to desk-based review, with six undergoing further compliance actions for late response. No compliance issues were identified.
Conclusion	Bermuda has made progress to address the recommendation. A number of liquidators were monitored in 2023 and 2024 for their compliance with the new record keeping obligations and were found to be compliant. No information is available on how liquidators have been selected for reviews. Bermuda should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Bermuda should – Report more details on monitoring actions with regards to liquidators’ obligation to keep records for a minimum period of five years, including information on how liquidators are selected for review.

Element A.3: Availability of banking information

7. Identification of trust beneficiaries by banks

 

Recommendation (A.3, framework)	Bermuda should ensure that banks are required to identify all of the beneficiaries (or class of beneficiaries) of trusts which have an account with a bank in Bermuda as required under the standard.
Underlying factor	Banks are required to identify individuals who ultimately own or control a trust as part of their customer due diligence measures. However, they are not required to identify all of the beneficiaries of a trust as only individuals who are entitled to a specified interest in at least 25% of the capital of the trust property must be identified. (see paragraphs 239 and 240 of the Bermuda’s 2017 Report for more information)
Summary of actions reported	The definition of beneficial ownership for legal arrangements in the context of financial institutions’ customer due diligence obligations was amended to include any natural persons having control over a trust, therefore eliminating the 25% threshold. Banks are required to identify all beneficiaries of trusts with a bank account in Bermuda. The look-through approach is common practice. The Monetary Authority supervises banks on a regular basis with regards to their customer due diligence policies, procedures and practices, which includes testing of customer due diligence files (which since 2018 reflects the changes to beneficial ownership requirements). Every bank undergoes a tailored on-site visit every two years. In 2023, one bank was selected on a risk basis for an on-site inspection. A planned on-site visit in 2024 was deferred pending a systems transformation. No material deficiencies have been identified so far and hence no enforcement actions have yet been taken.
Conclusion	Bermuda appears to have taken appropriate action to address the recommendation. The definition of beneficial owners of trusts having to be identified by banks has been expanded in line with the standard. Banks are subject to regular AML supervision and no issues have been identified so far. Bermuda is no longer required to report on this recommendation.
Status determined	Considered provisionally addressed in the context of the monitoring process, subject to detailed validation.
Actions required	No immediate action required.

Element C.3: Confidentiality

8. Information holders’ rights to access EOI requests

 

Recommendation (C.3, practice)	Bermuda should monitor that the EOI request is only disclosed in line with the international standard.
Underlying factor	The EOI Acts were amended in July 2015 to expressly annul the information holder’s rights to access an EOI request that would otherwise exist pursuant to the Supreme Court (Records) Act 1955. The amendments have not been sufficiently tested in practice. (see paragraphs 359 et seq. and 364 to 367 of the Bermuda’s 2017 Report for more information)
Summary of actions reported	Bermuda reported that the competent authority in all cases consults with treaty partners when it is asked to disclose the EOI request to the information holder in context of a court proceeding.
Conclusion	Bermuda has made progress to address the recommendation. It reports consulting treaty partners in all cases where the competent authority is asked to disclose an EOI request in the context of a court proceeding. No information is available on actual cases during the monitoring period to assess the implications for effective exchange of information. Bermuda should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Bermuda should – Report on how cases are handled where the competent authority is asked to disclose an EOI request to an information holder in the context of a court proceeding, supported by relevant statistics.

EOIR experience

Over the monitoring period 2023-2024, Bermuda received 70 requests and sent no requests. The United Kingdom, Colombia and Mexico were the top partners. Bermuda reported providing full and final responses in 66% of all the received requests and indicated 33% as pending requests. The remaining 1% (i.e. 1 request) represents a request withdrawn by the requesting jurisdiction. Bermuda reported an overall deterioration in the timeliness of their responses. Only 11% of requests were responded to within 90 days, 20% within 180 days and 59% within 1 year, which constitutes backsliding compared to the situation at the time of the 2017 Report. Also the provision of status updates deteriorated since the 2017 Report review period.

Nine members provided peer input on Bermuda. Peers reported general satisfaction in respect of their EOIR experience with Bermuda, but also some delays in answering their EOI requests and pending requests, as well as delays with, or absence of, status updates.

In light of the backsliding with regards to the timeliness of responses, a new recommendation is issued to Bermuda under Element C.5 (see paragraph 10). Bermuda is recommended to take suitable measures, including ensuring availability of adequate resources, to provide the requested information in a timely manner in all cases in line with the standard.

Bermuda is expected to submit a schedule for completion of steps to address the recommendation along with an update on the progress made by 31 March 2026.

Based on reported statistics and peer input on the inconsistent and delayed provision of status updates, a new recommendation is issued to Bermuda under Element C.5 (see paragraph 11). Bermuda is recommended to systematically provide status updates to its partners when it is unable to provide a response to a request within 90 days.

New developments having a bearing on the EOIR standard

No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Bermuda or have otherwise come to light.

Next steps

Bermuda should continue taking actions towards implementing the standard effectively.

Under the first round of enhanced monitoring, three new recommendations are issued to Bermuda.

9. Monitoring and enforcement of beneficial ownership identification duties in relation to trusts

 

Recommendation (A.1, practice)	Bermuda is recommended to monitor the implementation of the 2018 legal changes on requirements to identify beneficial owners of trusts in order to ensure the availability of accurate, adequate and up-to-date beneficial ownership information in line with the standard.
Underlying factor	Since 2018, exempted (non-licensed) trustees have beneficial ownership record keeping obligations. The definition of beneficial ownership of trusts has been expanded to include any natural person with control over the trust. The look-through approach is common practice in Bermuda. The implementation and enforcement in practice of these legislative amendments is yet to be ascertained.

10. Timeliness of exchanges

 

Recommendation (C.5, practice)

Bermuda is recommended to take suitable measures, including ensuring availability of adequate resources, to provide the requested information in a timely manner in all cases in line with the standard.

Underlying factor

The timeliness of Bermuda’s responses to requests for information deteriorated significantly over the 2023-2024 monitoring period. Only 11% of the incoming requests were responded to within 90 days and 20% within 180 days, while 33% remained pending. Bermuda explained that this backlog resulted from an unforeseen increase in other work handled by the same staff. The Bermuda authorities do not expect the situation to persist in the long term, but the backlog of EOIR cases remains significant.

11. Provision of status updates

 

Recommendation (C.5, practice)	Bermuda is recommended to systematically provide status updates to its partners when it is unable to provide a response to a request within 90 days.
Underlying factor	Peer input received on Bermuda during the monitoring period indicated that Bermuda did not provide status updates to EOI partners in respect of all requests where a full response could not be provided within 90 days. Almost 90% of the requests required a status update but it was provided only in some cases and sometimes only after having been specifically sought by the partner.

The following next steps are expected from Bermuda:

• For the new Recommendation 10 on timeliness of exchanges (Element C.5), Bermuda should submit to the PRMG – i) a schedule for completion of steps to address the recommendation and ii) an update, including details on the progress on such recommendation by 31 March 2026.

• Submit its next self-assessment, including on the new recommendations issued, in 2028 under the second round of enhanced monitoring.

• See also Chapter 1 (Scope and methodology), section on “PRMG decisions – Statuses determined and actions required”, which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”.

Views/response of the monitored jurisdiction

Bermuda remains committed to the work of the Global Forum on Transparency and Exchange of Information for Tax Purposes and the effective implementation of the EOI Standard. The valuable feedback received during the first Cycle of the Enhanced Monitoring process will contribute to the continued enhancement of our regime.

Note

← 1.  OECD (2017), Global Forum on Transparency and Exchange of Information for Tax Purposes: Bermuda 2017 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/9789264280083-en.