International data exchange – a norm
In the strife against tax avoidance and tax evasion the automatic exchange of fiscal data is progressively becoming specific, both on an EU level and on a worldwide scale. The international data exchange between tax authorities accelerated on a worldwide scale due to the adoption of the Foreign Account Tax Compliance Act (FATCA) in 2010. Thereafter the G20 countries have agreed by way of the Common Reporting Standard (CRS) in September 2013, to exchange fiscal data worldwide as from 2016. For the exchange of data among FATCA, CRS and EUSD a conceptual model4 IEOD-TA© was developed, which places financial institutions in a position to submit all data for FATCA, CRS and EUSD in a single message to the Tax Authority in their country and which places the Tax Authority in a position to automatically exchange the data respectively with the IRS, MCAA countries and EU countries (submitting and receiving) and to transfer the data to the Tax Authority itself to be utilized for the common fiscal processes for Levying and Monitoring.
In September 2014 the authors, Jorrit Geertsma (Project Manager at Tax and Customs Administration in the Netherlands) and Han Wijlens (Senior Consultant at Ordina), were requested to provide recommendations to Curaçao in preparation of the FATCA data exchange over tax year 2014, which had to be completed in conformity with an IGA clause with the USA by 30 September 2015. From their analysis it could be concluded that in the model case of Curaçao the IEOD-TA© can easily be applied. The research in Curaçao has taught that (the introduction of) international data exchange is more than simply providing an advice on “the implementation of an application”.