Alerts and Updates

Key Milestones for the Automatic Exchange of Information Framework

July 1, 2015

Automatic exchange of information protects the integrity of tax systems.

This Alert provides an indicative time table recording the key milestones in the Organisation for Economic Co-operation and Development's Automatic Exchange of Information framework agreed upon by the Early Adopters Group (which includes India, the United Kingdom, Isle of Man, Guernsey, Jersey, Netherlands, Cayman Islands and Belgium, among others). Automatic exchange of information protects the integrity of tax systems.

Key Milestone Dates in the Automatic Exchange of Information Framework


Pre-existing accounts (accounts open as of 31 December 2015)

Enhanced due diligence currently underway

New accounts (accounts opened from 1 January 2016)

New account opening procedures to record tax residence as per Common Reporting standard will need to be in place from 1 January 2016

Identification of high-value pre-existing accounts

Need to be completed by 31 December 2016

Identification of low value pre-existing accounts

Need to be completed by 31 December 2017

First automatic exchange of information (Anguilla, Argentina, Barbados, Belgium, Bermuda, British Virgin Islands, Bulgaria, Cayman Islands, Chile, Colombia, Croatia, Curaçao, Cyprus, Czech Republic, Denmark, Dominica, Estonia, Faroe Islands, Finland, France, Germany, Gibraltar, Greece, Greenland, Guernsey, Hungary, Iceland, India, Ireland, Isle of Man, Italy, Jersey, Korea, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Mauritius, Mexico, Montserrat, Netherlands, Niue, Norway, Poland, Portugal, Romania, San Marino, Seychelles, Slovak Republic, Slovenia, South Africa, Spain, Sweden, Trinidad and Tobago, Turks and Caicos Islands, United Kingdom, Uruguay)

September 2017

First automatic exchange of information (Albania, Andorra, Antigua and Barbuda, Aruba, Australia, Austria, the Bahamas, Belize, Brazil, Brunei Darussalam, Canada, China, Costa Rica, Grenada, Hong Kong (China), Indonesia, Israel, Japan, Marshall Islands, Macao (China), Malaysia, Monaco, New Zealand, Qatar, Russia, Saint Kitts and Nevis, Samoa, Saint Lucia, Saint Vincent and the Grenadines, Saudi Arabia, Singapore, Saint Maarten, Switzerland, Turkey, United Arab Emirates)

September 2018

 What Likely Needs to Happen Between Now and the Milestone Dates?

  • Process of review and monitoring of pre-existing accounts: The financial information to be reported with respect to reportable accounts includes all types of investment income (interest, dividends, income from certain insurance contracts and other similar types of income), as well as account balances and sales proceeds from financial assets.
  • Financial institutions under obligations to report: The financial institutions that are required to report under this framework include not only banks and custodians but also other financial institutions, such as brokers, certain collective investment vehicles and certain insurance companies.
  • Reportable Account Identification: Reportable accounts include accounts held by individuals and entities (which includes trusts and foundations), and the standard includes a requirement for look-through passive entities to report on the individuals that ultimately control these entities.

For Further Information

If you have any questions about the topics discussed in this Alert, please contact Saionton Basu in Duane Morris' London office, any of the attorneys in our India Practice Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.