The Road to Global Tax Transparency

The road to global tax transparency has been long, and at the forefront of international tax discussions for the while, but it has finally become a global reality. With the introduction of the Common Reporting Standard (CRS) in 2017, tax transparency is now impacting FIs in a much broader and global scope than it has in the past under the US qualified intermediary (QI) reporting rules introduced in 2002, and the Foreign Account Tax Compliance Act (FATCA) that came into effect in 2014. The pressure for the implementation of a centralized report unit and process is further exacerbated by the reporting due under the OECD's model mandatory disclosure rules (MMDR) and the EU's application of it under its DAC6 scheme.

The next big topic might be the introduction of TRACE (Tax Relief and Compliance Enhancement). This new OECD initiative, which is inspired by the U.S. Qualified Intermediary regime, has already been brought into force in Finland, and the European Union now also considers the implementation of TRACE on a European level. Tax transparency has also become a reality for investors. As international tax regulations become more stringent, taxpayers face challenges in reporting their onshore and offshore assets to tax authorities, with some using the voluntary disclosure facilities offered by some governments.

As a result, financial institutions are finding that their clients are increasingly requesting the institutions to provide tax reports consisting of tax information such as income, capital gains or wealth, in order to assist in filing tax returns according to the respective tax law. And the demand for client tax reporting services is growing.

With all this data exchange and client requirements, FIs are having to adapt quickly to meet the demands of their clients and the authorities. The ultimate question is whether FIs will keep their reporting in-house or outsource it to a specialized service provider.