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Automatic Exchange of Information - Middle East

The OECD’s Common Reporting Standard (“CRS”) went live across the following countries in the Middle East with effect from 1 January 2017:


  • Pakistan;

  • India;

  • The UAE;

  • Saudi Arabia;

  • Kuwait;

  • Qatar; and

  • Bahrain.


CRS places compliance obligations on all Financial Institutions operating in those jurisdictions.  Given that over 100 jurisdictions are participating in CRS, the impact will be significantly greater than FATCA.  Whilst CRS leverages heavily on FATCA, there are a number of subtle differences which have become evident in the first wave of countries which implemented CRS in  2016.


This means that all Financial Institutions (“FI”) operating in those jurisdictions must already have updated their on-boarding procedures to capture information ready for submitting the first returns in 2018. 


Implementation of CRS will impose a number of challenges in a region where there is no concept of tax residence and a substantial mobile expatriate population base.  Given that the focus is on the transient concept of tax residence rather than citizenship, robust procedures will need to be put in place to capture changes.


Our expert team of specialist advisers drawn from HMRC, big-4 accountancy, legal firm and industry will be able to share with you their practical experience of CRS implementation within the first wave of jurisdictions, with their deep knowledge of the region from implementing over 50 AEoI implementation projects.

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