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Course Application

CRS-Automatic Exchange of Information in Tax Matters

Objectives of the Course.

This course is of 1 credit, with our ever-popular Moritz Naef

Meets 12 hours: Thursdays 19:00-22:00 and Saturdays, 14:00-17:00. Mar23/25, April 6/8, 2017

This is not in Pericles regular schedule but is Professor Naef’s personally authored, one credit course.

Russia (along with some 100 other countries) has committed to automatically exchanging information on bank accounts (and other financial accounts) with other countries as part of an OECD initiative to combat tax evasion. As a consequence, a bank in country A that keeps an account for a client (or beneficial owner) who is tax resident in country B must report information relating to the client (or beneficial owner) and his/her bank account (balance, revenues, etc.) to the tax authority in country A, which will then transmit this information to the tax authority in country B.  There is quite a bit of confusion and misinformation as to how this will work in practice.

Professor Naef proposes to address the background and aims of the initiative, the legal basis, the mechanism for reporting, who must report, and whose accounts must be reported.  He plans to spend a large amount of time on case studies to make sure students understand how the rules will be applied in practice.  He also hopes to bring in one or more bankers as guest speakers in the class.  

Tentative Content

  1. Background and aims of the AEoI Initiative
  2. Legal basis (Competent Authorities Agreement, Common Reporting Standards [CRS], commentaries, appendices)
  3. Mechanism
  4. Reporting persons ("Who must report?")
  5. Reportable persons ("Whose accounts must be reported?")
    1. Individuals
    2. Entities (financial institutions, active/passive non-financial entities)
  6. Reportable information ("What information must be reported?")
  7. Case studies
  8. Other transparency initiatives (in particular: UBO register in EU)