Exchange of information and the fight against cross-border tax evasion

As a ramification of globalisation and technological advancement, cross-border transactions have seen an immense increase over the years, and this involves financial flows from one country to the other. Though a preeminent means by which individuals and companies engage in business opportunities, cross-border transactions also represent a predominant medium to hide wealth and related income to avoid tax obligations from where one is subject to tax. This leads to cross-border tax evasion which occurs when individuals and multinational companies use cross-border transactions to hide income and wealth to avoid various tax obligations where they are subject to tax. As a result of the impact of cross-border tax evasion, countries have been impelled to cooperate to scout out remedies to eliminate it. Exchange of Information (EOI) has over the years emerged as a distinctly preponderant remedy and a global tool used by countries worldwide to fight cross-border tax evasion. EOI is the process by which countries share financial information or taxpayer information. EOI is enshrined in various multilateral and bilateral conventions and agreements between governments. One of the purposes of EOI is to promote cooperation and transparency between governments in the elimination of cross-border tax evasion. This article discusses the concept of EOI and its impact on cross-border tax evasion.

Cross-border tax evasion

Cross-border tax evasion arises when taxes owed to a government are illegally transferred offshore to avoid or evade the payment of those taxes. This has been a blight on the economies and progress of developing and developed countries for decades. The impact of cross-border tax evasion on developing and developed economies cannot be disdained. Countries lose a colossal shedload of revenue to cross-border tax evasion each year. In 2022, Jeanne Whalen in an article published by the Washington Post, reported that countries worldwide lose over US$427billion yearly to cross-border tax avoidance and evasion schemes, with the United States alone losing over US$90billion. This has made cross-border tax evasion disastrous and inhibiting to efforts by governments to mobilise revenue to promote sustainable economic development. In 2018, a Singaporean oil trader was found guilty of evading tariffs worth US$54million on 1.3 million tonnes of oil products that were imported to China. Again, the Tax Justice Network in 2021 reported that countries are losing US$483billion to global tax abuse caused by high-net-worth individuals and multilateral corporations. The report further stipulated that “of the US$483billion in tax abuse, US$312billion is lost to cross-border corporate tax abuse by corporations and US$171billion is lost to offshore tax evasion by wealthy individuals”.  These wealthy individuals are most often referred to as High-Net-Worth-Individuals.

Cross-border tax evasion, high-net-worth-individuals, tax havens

A major attribute of cross-border tax evasion is the avoidance of payment of taxes owed to governments by high-net-worth individuals. High-net-worth-individuals often refer to persons with at least US$1million in liquid financial assets. These individuals transfer their assets and wealth to tax havens or offshore financial centres. Tax havens are attractive because they provide very low and, in some cases, no corporate taxes for businesses set up there. Tax havens are often referred to as secrecy jurisdictions as they are well-known to be discreet about sharing information and lack transparency. Tax havens, by their nature, tend to attract a high number of foreign investors.  Countries and territories like Switzerland, Netherlands, Jersey, Luxembourg, Panama, and Mauritius are often referred to as tax havens. Tax havens have contributed immensely to cross-border tax evasion over the years and have deprived countries of their revenue.

III. Exchange of Information (EOI)

Several remedies to cross-border tax evasion have evolved over the years; however, predominant among them is Exchange of Information (EOI). EOI involves the sharing and exchange of foreseeably relevant financial information or taxpayer information between countries. For a successful EOI regime between countries, there must be availability of information, access to information, the ability to exchange information, and the willingness of governments to exchange information. An EOI mechanism must be effective, ensure confidentiality of the information and data received, cover all the relevant partners, be timely, and must respect rights and safeguards. EOI enables tax authorities to obtain information from foreign countries that is necessary to enforce their domestic tax laws and to assess and collect taxes owed. For accuracy and efficiency in the reporting and collection of taxes, individuals and businesses in most jurisdictions are required to keep accurate records of their income and expenses, calculate their tax liability based on those records and the applicable tax laws, and file tax returns on time with the tax authority. The tax authority may also require additional information or documentation to support the tax return, such as bank statements or invoices. The tax authorities must also ensure that they are properly administering their tax systems and enforcing their domestic laws by collecting the taxes owed, conducting regular audits and investigations to detect and deter tax evasion and fraud, and providing guidance and support to taxpayers to help them comply with their tax obligations.

EOI is imbibed in various multilateral conventions, central among them is the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Before the passage of this convention, EOI provisions were included in double taxation treaties and tax information exchange agreements, and took the form of Exchange of Information on Request (EOIR).

Multilateral Convention on Mutual Administrative Assistance in Tax Matters

The Multilateral Convention on Mutual and Administrative Assistance in Tax Matters (the Convention) is a multilateral legal instrument on EOI and went into effect in 1988. The Convention was formed as a result of the Organisation for Economic Cooperation and Development (OECD) and the Council for European Union’s quest to facilitate international cooperation between jurisdictions to counter international tax evasion as well as other non-compliance mechanisms by taxpayers. In 2010, the Convention was amended by a protocol to allow more countries to adopt it as well as amend some provisions to match up to international standards and best practices for the exchange of information for tax purposes. The Convention currently has 146 participating jurisdictions and is regarded by the OECD as the “most comprehensive and wide-ranging legal instrument for internationally exchanging information”. The Convention has been significant in the cooperation between countries to exchange information for the avoidance of cross-border tax evasion and its chapter III forms the legal basis for the five main types of EOI, which have been briefly discussed in preceding paragraphs. The Convention applies to all types of taxes and includes a secrecy rule under article 22 which provides that a high standard of confidentiality must be maintained during the exchange of information between contracting states. The secrecy rule/provision serves as a safeguard and protection of the rights of individuals and organisations whose information is the subject of an exchange under the Convention. Information by contracting states must be safeguarded to ensure it is not accessible by persons who must not be privy to them.  Information received must be used for tax purposes only, including cross-border tax evasion, and when necessary, used in preventing corruption, anti-money laundering, and others. Like most International conventions and bilateral agreements, the Convention must be ratified before it can be domesticated and implemented under the laws of most participating countries.  Some countries go as far as amending their laws as well as passing new laws to better accommodate EOI standards.

The five types of EOI under the Convention

Exchange of Information on Request (EOIR) was the first global framework to be adopted by the OECD.  EOIR entails the request of taxpayer information and transactions by a tax authority of a participating country, which must be provided by the country the information is being requested from.  Under the EOIR, information such as bank statements, financial account details, and assets are requested. The information requested must be provided to the requesting country in a timely and confidential manner. The OECD in ensuring the effective implementation of the EOIR standard conducts periodic peer reviews on participating countries. Depending on the level of compliance, countries are categorized as compliant, largely compliant, partially compliant, or non-compliant.

Automatic Exchange of Information (AEOI) is when by mutual agreement and procedure two or more countries automatically exchange information amongst themselves. AEOI is facilitated by the Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Account Information. The purpose of AEOI is to increase transparency and enhance the fight against cross-border tax evasion by enabling tax authorities to automatically exchange information on financial accounts held by their residents in other countries. The Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI Standard) is the framework used by countries to exchange information under AEOI. Participating countries under the AEOI Standard agree to exchange financial account details, such as bank accounts, insurance contracts, and other financial assets of their residents held in foreign countries automatically. The AEOI standard has been adopted by over 100 countries and information exchanges are carried out on an annual basis. Top of Form In efforts to strengthen AEOI, the OECD adopted the Common Reporting Standard to prescribe a common standard for AEOI between participating jurisdictions.

Spontaneous Exchange of Information (SEOI) involves the sending of foreseeably relevant taxpayer information from one country to the other without any prior request from the receiving country. SEOI happens when the country sending the information believes it will be of interest to the receiving country.

Simultaneous tax examination is when two or more tax authorities of participating countries agree upon the request of one of them to simultaneously examine the tax activities of a person(s) that is of common interest to them. Under simultaneous tax examination, each tax authority examines the person’s tax activities in their country and exchanges the information discovered between themselves.

Tax examination abroad is when a country from whom taxpayer information is requested allows the officials from the tax authority of the country requesting such information to be present in the country during the examination of the tax matter requested.

EOI and the fight against cross-border tax evasion

The impact of EOI in eliminating cross-border tax evasion cannot be disparaged. The OECD has described EOI as the means “to achieving global tax co-operation through the implementation of international tax standards and other instruments to put an end to bank secrecy and tackle tax evasion.”   The OECD, in its 2022 Global Forum Annual Report on EOI matters, stated that “more than €114billion of additional revenues – tax, interests, penalties – have been identified so far thanks to voluntary disclosure programmes and offshore tax investigations since 2009”. Ensuring the efficacy of EOI involves, at the very core, the private sector, governments, international organisations and civil society.

International organisations, such as the OECD, United Nations (UN), and the Financial Action Task Force (FATF) have been key in the implementation and enforcement of EOI standards.  The OECD facilitates the passage and implementation of global EOI standards across the globe. The Global Forum on Transparency and Exchange of Information (Global Forum) of the OECD oversees a transparent and effective exchange of information regime for participating countries. The UN’s Committee of Experts on International Cooperation in Tax Matters was created to adapt standards and guidelines to promote international tax coordination between countries. As an international organisation, FATF was established in 1989 as an initiative to formulate policies to combat anti-money laundering and terrorist financing as well as promote global standards to help eliminate acts such as cross-border tax evasion. The International Monetary Fund and the World Bank also provide technical assistance to FATF’s member-states to promote compliance and enforcement, and strengthen their tax systems to eliminate cross-border tax evasion. They also prepare periodic reports and working papers that discuss EOI and cross-border tax evasion. Non-governmental organisations (NGOs) also play a key role in ensuring the enforcement of EOI standards. One such NGO is the Tax Justice Network which advocates extensively against cross-border tax evasion and tax havens.

It is important to also note that EOI cannot be effectively enforced without the important role played by participating countries. As stated earlier, most countries must ratify and domesticate EOI conventions and standards passed by international organisations before they can be effectively implemented.

Though EOI has been effective to some extent in the fight against cross-border tax evasion, the current EOI regime has certain roadblocks that facilitate cross-border tax evasion at a prodigious scale.

Roadblocks to EOI and the fight against cross-border tax evasion

Some challenges to the effective and efficient implementation of EOI in the fight against cross-border taxation evasion have been discussed in the preceding paragraphs.

EOI sanctions regime

The provisions on sanctions in EOI conventions and standards do not place strict sanctions on countries that are non-compliant with the rules set out in them. For instance, article 22 paragraph 2 of the Multilateral Convention on Mutual and Administrative Assistance in Tax Matters (the Convention) provides that “sanctions for the violation of such secrecy in that State will be governed by the administrative and penal laws of that State”. Similarly, the Commentary on Section 5 concerning Confidentiality and Data Safeguards of the AEOI Standard, in Paragraph 3 sub-paragraph 3.1 espouses: “Penalties and Sanction: Domestic law must impose penalties or sanctions for improper disclosure or use of taxpayer information, and tax administrations must impose these penalties and sanctions against personnel who violate security policies and procedures to deter others from engaging in similar violations. To ensure implementation, such laws must be reinforced by adequate administrative resources and procedures. Tax administrations should implement a formal sanctions process for personnel and third-party providers who fail to comply with established information security policies and procedures. Policies should consider both civil and criminal sanctions for unauthorised inspection or disclosure”. These provisions give the mandate to impose sanctions on the participating countries.  Participating countries are encouraged to impose strict sanctions and, in some cases, criminal prosecution on individuals found guilty of cross-border tax evasion. Thus, OECD’s Global Forum, as the global regulatory body to ensure compliance of participating jurisdictions to EOI standards, conducts periodic peer reviews and does not have the mandate to impose sanctions on non-compliant countries. What this does is to only name and shame non-conforming and non-compliant countries without serious implications or sanctions. While the Global Forum and other international governing bodies can provide recommendations and assistance, most of these EOI standards do not mandate them to impose sanctions or penalties on non-compliant countries. This means countries may decide to be non-compliant and not face any significant repercussions.

• Sanctions regime on tax havens

The current sanctions regime is not strict on tax havens considering the havoc caused to efforts by global regulatory bodies and countries to eliminate cross-border tax evasion. Tax havens and secrecy jurisdictions target loopholes in the various EOI standards to operate. Some tax havens go as far as selling passports and residences to investors and individuals. For instance, some countries choose voluntary secrecy rather than implementing the AEOI standard.

Financial Account Information Provision

The AEOI standard exempts some financial institutions, such as pension funds, from reporting information. This exemption excludes information that may be important in detecting cross-border tax evasion. The AEOI Standard provides that each Reporting Financial Institution must report “the account balance or value (including, in the case of a Cash Value Insurance Contract or Annuity Contract, the Cash Value or surrender value) as of the end of the relevant calendar year or other appropriate reporting period or, if the account was closed during such year or period, the closure of the account” for each Reportable Account of such Reporting Financial Institution. This provision allows only the balance of accounts and not its credit or account activity to be reported at the end of the year. This provision is not favourable in the agenda to eliminate cross-border tax evasion. Where an account balance would not provide the competent authorities (competent authorities are tax or revenue authorities) of the requesting country with the relevant information needed to ascertain whether an activity has resulted in cross-border tax evasion, it may render EOI ineffective and inefficient. This is because the country requesting the information will not have sufficient information to determine whether there has been cross-border tax evasion.

Due diligence rule on the Automatic Exchange of Information on an annual basis

The due diligence procedure rules, under Section II of the AEOI Common Reporting Standard, provide that “An account is treated as a Reportable Account beginning as of the date it is identified as such under the due diligence procedures in Sections II through VII and, unless otherwise provided, information concerning a Reportable Account must be reported annually in the calendar year following the year to which the information relates”. What this means is that once an account has been identified as a reportable account, it must be reported annually in the calendar year following the year to which the information relates, unless otherwise specified. Thus, if a financial institution has identified an account as a reportable account under the due diligence procedures, it must report information about that account to the relevant tax authorities on an annual basis for the calendar year following the year in which the information was collected. This reporting obligation applies unless there is an exception or exemption under the AEOI rules. This provision limits the frequency of AEOI between participating jurisdictions and as a result, may cause a time lapse in detecting activities by individuals and multinational corporations which may lead to cross-border tax evasion.

 

1. The way forward: A stronger EOI regime in the fight against cross-border tax evasion

While it is true that some countries continue to experience significant losses in tax revenues due to cross-border tax evasion, the efficiency and effectiveness of EOI in preventing these losses depends on various factors. Simply having an EOI regime in place is not enough to prevent cross-border tax evasion and profit shifting by multinational companies. For the current EOI regime to be more effective in eliminating cross-border tax evasion, the following recommendations may be considered:

Implementation of a strict EOI sanctions regime

The current EOI regime must allocate some level of mandate to the OECD and other global and regional bodies in charge of EOI to impose strict sanctions on participating countries that are non-compliant. The rules, if amended, must provide strict sanctions against countries noted for being consistently non-compliant and providing inaccurate or false information to protect the interests of their citizens or investors. Additionally, the new regime may incorporate rules to suspend countries that are constantly non-compliant from participating in its activities until they adopt measures to ensure that they are compliant with the EOI conventions and standards they have signed onto. Leaving the mandate to prescribe sanctions on other participating jurisdictions in the hands of other participating jurisdictions is insufficient to ensure an effective and efficient EOI regime. Additionally, participating countries may impose sanctions, such as the revocation of the license of corporations to operate within these countries, to facilitate compliance with EOI standards in the quest to eliminate cross-border tax evasion.

The sanctions, if established, must have a clear and objective criterion for determining non-compliance and ensure that sanctions are applied consistently and proportionately to all participating countries. It is also important to ensure that the imposition of these sanctions is accompanied by adequate monitoring and oversight to ensure that they are implemented effectively and fairly.

Update of the Rules of Financial Reporting Standard

The current EOI regime on yearly bank statements under the automatic exchange of information should be amended to include all account activities or credit. All account transactions should be reported at the end of the reporting period without limiting it to just account balance or value at the end of the reporting period. By allowing for the reporting of all account activities and transactions, the countries receiving such information would have access to more detailed information which would enable them to determine through analysis and verification of the activities whether there has been a cross-border tax evasion. This would help to eliminate cross-border tax evasion as individuals and multinational corporations would be unable to cover up their tax evasion activities, such as transferring monies or assets from one account to another nearing the reporting period to show a zero or less account balance. The amendment would also promote an efficient and effective EOI regime within tax havens and financial centres to eliminate cross-border tax evasion. This would ultimately enhance the transparency and fairness of the global tax system, prevent tax avoidance and evasion, and increase overall compliance with tax regulations.

Enhancing transparency and accountability of tax havens

Transparency and accountability of tax havens and financial centres are key factors in ensuring a reliable and effective EOI regime. There is a growing need for greater transparency and accountability in the information exchange process, especially with tax havens and financial centres. In making this recommendation, it is important to consider that if a tax haven or other non-cooperative jurisdiction does not sign onto, ratify and domesticate an EOI convention or standard, they will not be subject to the reporting and transparency requirements of these instruments. In such cases, other measures may be taken to encourage greater transparency and accountability in tax matters. For example, some countries have enacted unilateral measures to combat cross-border tax evasion and require their financial institutions to report information on accounts held by non-residents to their tax authorities, which may then be shared with other countries through bilateral or multilateral information exchange agreements. The United States, in 2010, passed its Foreign Account Tax Compliance Act (FATCA) as an initiative to combat cross-border tax evasion by its taxpayers. The Act mandates all US taxpayers who have offshore accounts and assets in other jurisdictions to report them to the Internal Revenue Service, failure to do that would incur penalties as prescribed by the Act.  Foreign financial institutions inclusive of investment banks, brokers and others are also mandated under the Act to report to the IRS information on accounts or assets owned by United States citizens. Countries may pass similar laws to assist in accessing and receiving information from tax havens that are difficult to deal with.

In addition, international organisations, such as the OECD’s Global Forum, may work with non-cooperative jurisdictions to encourage them to adopt international standards and best practices; and may take steps to identify and address potential risks or gaps in the international tax framework. Also, the EOI regime must ensure that tax havens and financial centres abide by the laid down rules and procedures and not get away with non-conformity by any means. For instance, tax havens and financial centres should not be allowed to choose voluntary compliance instead of the Common Reporting Standard of the AEOI. This allows them to withhold important information and data concerning information requested by a State on grounds of suspicious cross-border tax evasion activities.

1. Conclusion

The effectiveness and efficiency of EOI in the fight against cross-border tax evasion cannot be realised without concerted efforts by relevant stakeholders, most importantly countries. The recommendations made in this article to enhance the effectiveness of EOI in the fight against cross-border tax evasion can only be feasible through the commitment of participating countries to cooperate in the exchange of information.

References:

1. OECD Convention on Mutual and Administrative Assistance in Tax Matters.

 

2. OECD Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Account Information.
3. OECD Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition, (2017).
4. Xavier Oberson, International Exchange of Information in Tax Matters: Towards Global Transparency, 2^nd Edition (2018).
5. Gabriel Zucman, “The Hidden Wealth of Nations: The Scourge of Tax Havens”, (University of Chicago Press, 2015).
6. Emmanouil Kitsios, Joao Jalles, and Genevieve Verdier, Tax Evasion from Cross-Border Fraud: Does Digitalization Make a Difference? IMF Working Paper, (November 2020) at 4 (arguing that, “Such tariff evasion could significantly erode revenue mobilization efforts, particularly in low-income countries. Even in more advanced economies, such evasion is costly”).
7. De Simone, R. Lester, and K. Markle. “Transparency and tax evasion: evidence from the Foreign Account Tax Compliance Act (FATCA)”, Journal of Accounting Research, 58 (2020) at 105-153.
8. Mark Pieth, “Global Exchange of Information on Tax Matters: Are We There Yet?” Journal of Money Laundering Control”, 22, No. 1 (2019) at 5-13.
9. Elisa Casi, Christoph Spengel, Barbara M. B. Stage, Cross-Border Tax Evasion After the Common Reporting Standard, Game Over?, Annual Conference on Taxation and Minutes of the Annual Meeting of the National Tax Association, Vol. 111 (2018) at 2 (arguing that, “Cross-border tax evasion, however, deprives jurisdictions around the world from substantial tax revenue every year”).
10. Richard Murphy, “The Automatic Exchange of Information: A Quiet Revolution?” British Tax Review, 4 (2016) at 434-448.
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12. Paul Vandenberg and Alan Myrold, Exchange of Information to Combat Tax Evasion, Asian Development Bank Institute Policy Brief, (May 2015) at 1 (stating that “Tax evasion is a global concern that reduces government revenue and undermines trust in the tax system” and “The increase in cross-border transactions, made possible by advances in information and communication technology, has provided opportunities for aggressive cross-border tax evasion”).
13. Johannesen, Niels, and Gabriel Zucman, “The End of Bank Secrecy? An Evaluation of the G20 Tax Haven Crackdown”American Economic Journal: Economic Policy, (2014) at 65-91.
14. Achim Pross and Raffaele Russo, OECD, International – The Amended Convention on Mutual Administrative Assistance in Tax Matters: A Powerful Tool to Counter Tax Avoidance and Evasion, (2012).
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16. Global Forum on Transparency and Exchange Information for Tax Purposes: Raising the Bar on Tax Transparency, 2022 GLOBAL FORUM ANNUAL REPORT.
17. Jeanne Whalen, Tax cheats deprive governments worldwide of $427 billion a year, crippling pandemic response: study, Washington Post, (November 19, 2022), https://www.washingtonpost.com/us-policy/2020/11/19/global-tax-evasion-data/#:~:text=Tax%20cheats%20deprive%20governments%20worldwide%20of%20%24427%20billion,Whalen%20November%2019%2C%202020%20at%207%3A01%20p.m.%20EST.
18. The IMF and the Fight Against Illicit and Tax Avoidance related Financial Flows, International Monetary Fund, (March 8, 2021) (stating that, “they can drain foreign exchange reserves, affect asset prices, lower tax receipts, distort competition and reduce government revenue)” https://www.imf.org/en/About/Factsheets/Sheets/2018/10/07/imf-and-the-fight-against-illicit-financial-flows#:~:text=Illicit%20and%20tax%20avoidance%20related%20financial%20flows%20%28ITAFFs%29,tax%20receipts%2C%20distort%20competition%20and%20reduce%20government%20revenue.
19. Tax Justice Network, “Losses to OECD tax havens could vaccinate global population three times over, study reveals by Mark Bou Mansour”, (November 16, 2021) Losses to OECD tax havens could vaccinate global population three times over, study reveals – Tax Justice Network.
20. Alex Cobham, “Why Automatic Information Exchange Fails to Crack Down on Illicit Financial Flows,” The Conversation, July 19, 2019, https://theconversation.com/why-automatic-information-exchange-fails-to-crack-down-on-illicit-financial-flows-120754.
21. Andy Hoffman and Alfred Cang, “Singaporean Oil Trader Gets 12 Years in Chinese Prison Over Tariff Evasion”, Bloomberg, (October 1, 2018), https://www.bloomberg.com/news/articles/2018-10-01/ex-gunvor-oil-trader-gets-12-years-in-chinese-prison-on-tariffs.

22. Niall McCarthy, Tax Avoidance Costs the U.S. Nearly $200 Billion Every Year, FORBES, (March 23, 2017), https://www.forbes.com/sites/niallmccarthy/2017/03/23/tax-avoidance-costs-the-u-s-nearly-200-billion-every-year-infographic/#64af0b272f0.
23. Yuji Miyaki, How Developing Asia Can Better Fight Tax Evasion, Asian Development Blog, (15 April 2016), (argues that “Developing countries, including those in Asia, are also struggling to strengthen their tax systems—and counter tax evasion … Tax evasion is a global problem, and Asia’s developing countries are certainly not immune from it)” https://blogs.adb.org/blog/how-developing-asia-can-better-fight-tax-evasion.
24. Tax Justice Network, “Losses to OECD tax havens could vaccinate global population three times over, study reveals by Mark Bou Mansour”, (November 16, 2021) Losses to OECD tax havens could vaccinate global population three times over, study reveals – Tax Justice Network).
25. OECD website, https://www.oecd.org/ctp/exchange-of-tax-information/.
26. OECD Website, (stating that “Tax avoidance and tax evasion threaten government revenues”) https://www.oecd.org/ctp/fightingtaxevasion.htm.
27. Summary of FATCA Reporting for U.S. Taxpayers, https://www.irs.gov/businesses/corporations/summary-of-fatca-reporting-for-us-taxpayers.