The Clock Is Ticking for CRS (AEOI) Implementation

There is so much buzz about CRS and BEPs now that the rest of the world has adapted and adopted the United States’ much maligned FATCA initiative.  I’m enjoying going to seminar after seminar as I come to terms with how this impacts our firm and our clients.

CRS is essentially FATCA on steroids – which is why the U.S. has not signed up to it.

So far, nearly 100 countries have signed up and the first group of early adopters (mainly the Europeans) go live in 2017.  So in 2017 they will report 2016 accounts.

This essentially  means that CRS goes live in January 2016.  While some jurisdictions continue to be in denial (I’m not naming names), others like the Cayman Islands are staying ahead of the curve. It recently (October 2015) updated regulations to exclude certain Cayman incorporated entities from the CRS net.  Have a look at the language on page 25 – http://www.gov.ky/portal/pls/portal/docs/1/12254315.PDF

I suspect that other jurisdictions will soon follow.  Practitioners in my space are taking note.  There is likely to be quite a difference between the theory and the practical impact of BEPs / CRS initiatives.