Towards Automatic Exchange of Information

This article describes the various steps that led towards automatic exchange of information as the global standard and the issues that remain to be solved.

First, the various competing models of exchange information, such as Double Tax Treaty (DTT), TIEA’s, FATCA or UE Directives are described with a view to show how they interact between themselves. Second, the so-called Rubik Strategy is summarized and compared with an automatic exchange of information (AEOI). As it will be demonstrated, this Rubik System was an alternative attempt to find a compromise between the privacy of the taxpayer on the one hand, and compliance in the taxpayer’s state of residence, on the other hand. This proposal appears not to be a possible long term alternative solution to AEOI. Indeed, in the meantime the wheel has moved towards the AEOI as the future global standard. In this respect, FATCA has emerged as a major driver in this area and the implementation of a inter-governmental agreement (IGA) all over…