Host Country Tax Authorities (HCTAs) cannot report CRS data to other HCTAs based on having signed up to the AEoI and the Multilateral Competent Authority Agreements alone.
To trigger the ability to report to other HCTAs bilateral agreements must also be agreed. This process includes agreed procedures for keeping data safe.
147 bilateral agreements have yet to be triggered (or perhaps more accurately I cannot locate them).
Only Early Adopters are listed here. Also, only those Early Adopters for whom reporting relationships are not in evidence are listed here.
Barbados, Curacao and Trinidad and Tobago are clear outliers.
Trinidad and Tobago have yet to sign FATCA and CRS into local law. For this reason, one hesitates to include them among the population of Early Adopters. However, Trinidad and Tobago has not yet been removed from the official list of Early Adopters.
Invitation – if you have links to these bilateral agreements and I have simply missed them, please share a link with me: firstname.lastname@example.org and I will share.