21.07.2015 Views

handbook-tb

handbook-tb

handbook-tb

SHOW MORE
SHOW LESS

You also want an ePaper? Increase the reach of your titles

YUMPU automatically turns print PDFs into web optimized ePapers that Google loves.

Diane Ringcase of an individual) of each Reportable Person that is an AccountHolder.” 49Due diligence: To ensure meaningful and effective provision ofinformation, reporting financial entities must perform a specified levelof due diligence aimed at securing accurate information regarding theidentity of the account holder. Different standards of diligence areapplied depending upon when the account was created, its contents,its value and other information known to the financial entity.4.3.3 Model Competent Authority AgreementThe CAA is drafted as a bilateral agreement between two jurisdictionsto commit to the automatic exchange of financial account information.Pursuant to the agreement, the countries agree to have domesticrules requiring financial institutions to report accounts and follow duediligence procedures consistent with the CRS and the terms of the specificCAA. Additionally, the signatories confirm that they have: (a) theappropriate safeguards to protect the confidentiality of taxpayer data;and (b) the infrastructure necessary for effective exchange (includingmechanisms for “timely, accurate, and confidential informationexchanges, effective and reliable communications, and capabilities topromptly resolve questions and concerns about exchanges or requestsfor exchanges”). 504.3.4 Developing country analysis4.3.4.1 OverviewA range of developing countries have expressed interest in automaticexchange of information. Income tax evasion poses a serious fiscalchallenge for many developing countries which rely substantiallyon the income tax base. Current methods for obtaining informationlocated outside the jurisdiction can be costly or unavailable. Treatiesgenerally permit exchange of information only upon request (a processthat can be burdensome in terms of time, money and expertise).49Ibid., at 29.50Ibid., at 21-22.548

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!