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Transparency and disclosureCommon Reporting Standard,” 45 which the G20 approved: “Weendorse the Common Reporting Standard for automatic exchange oftax information on a reciprocal basis and will work with all relevantparties, including our financial institutions, to detail our implementationplan at our September meeting.” 46As a follow-up to its February 2014 document, the OECDreleased its more comprehensive “Standard for Automatic Exchangeof Financial Account Information in Tax Matters” in July 2014. 47 TheJuly report included: (a) the text of a Model Competent AuthorityAgreement (CAA) for automatic exchange of certain tax information;(b) the Common Reporting Standard (CRS); and (c) Commentaryintended to facilitate uniform implementation of the agreement andstandard. Exchange of information under this system requires thateach country take two basic steps.First, countries must implement any domestic law changes necessaryfor: (a) requiring financial entities to gather and report the designatedinformation; and (b) ensuring appropriate protection of taxpayerdata. Second, countries (through their competent authorities) mustagree to the exchange on an automatic basis and must set the termsof that exchange (for example, the CAA). The report urges that thisagreement be executed under the legal framework of the MultilateralConvention on Mutual Administrative Assistance in Tax Matters (seesection 5.4 below) because it allows for more than one country to enterinto such a competent authority agreement, potentially reducing theamount of negotiating a country must do. Alternatively, the competentauthority agreement could be executed under a bilateral tax treatybetween two countries.45OECD, Standard for Automatic Exchange of Financial Account Information:Common Reporting Standard (Paris: OECD, 2014), available at http://www.oecd.org/ctp/exchange-of-tax-information/automatic-exchange-financial-account-information-common-reporting-standard.pdf.46Communiqué, G20 Meeting of Finance Ministers and Central BankGovernors, supra note 44.47OECD, Standard for Automatic Exchange of Financial Account Informationin Tax Matters (Paris: OECD, 2014), available at http://www.oecd.org/ctp/exchange-of-tax-information/standard-for-automatic-exchange-offinancial-information-in-tax-matters.htm.545

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