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Transparency and disclosureMoreover, many developing countries have a more limited treaty network(even including TIEAs), and may not have treaties with key taxhaven jurisdictions (used by their residents to avoid the developingcountry income tax). Thus, some developing countries are amongthose who have committed to early adoption of the CRS (see section4.2.4 above)4.3.4.2 Advantages of the Common Reporting Standard and theCompetent Authority AgreementThe overall automatic exchange of information project advances thepotential for meaningful income tax enforcement. Widespread disseminationof relevant taxpayer information to the appropriate taxingauthorities enhances real enforcement and, more broadly, alerts taxpayersto the risks of tax evasion. As noted in section 4.3.4.1 above, currentinformation exchange mechanisms can be too burdensome to serve asa regular component of tax enforcement. Automatic, bulk provisionof the information enumerated in the CRS would significantly reducethe costs of acquiring that information through existing mechanisms.Additionally, the automatic nature of the delivery reduces the opportunityfor pressure, leverage and corruption in tax administration.The scope of taxpayers whose accounts are covered by the CRSfurther increases the value of the information exchange. The decision toinclude entities and not just individuals, and to reach trusts and otheroften opaque holding structures, expands the coverage of this automaticexchange of information system beyond that of some other programmes.4.3.4.3 Limitations of the Common Reporting Standard and theCompetent Authority AgreementThe advantages of the CRS and CAA described above essentially reflectthe reduced costs and difficulties of acquiring information comparedwith obtaining it via an existing bilateral treaty. But the ability to participatein the CRS and CAA is currently contingent upon: (a) meetingthe standards necessary to commit to providing — not just receiving— information (required reciprocity); and (b) getting the key jurisdictionto sign a CAA (participation).549

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