The Common Reporting Standard (CRS) is the result of the drive by the G20 nations to develop a global standard for the automatic exchange of financial account information. Developed by the OECD, the CRS aims to maximise efficiency and reduce costs for financial institutions by drawing heavily on the approach taken to implementing FATCA.
There are, however, some distinct differences between the two systems, driven to a large extent by the multilateral nature of the CRS compared to FATCA and the US specific features of FATCA such as reporting on the basis of citizenship as well as tax residence, compared to only tax residence under the CRS, and the FATCA withholding tax which introduces additional features into the reporting process that are not needed when implementing the CRS.
In October 2014, 45 jurisdictions signed a multilateral competent authority agreement to start exchanging information using the CRS framework from 2017. A further 4 signed the same agreement with a commitment to begin exchanging information in 2018. Since then many more jurisdictions have either signed the multilateral competent authority agreement or made a commitment to automatic exchange. The regulations that require UK financial institutions to identify, maintain and report information for exchange with these jurisdictions, The International Tax Compliance Regulations 2015, came into force on 15 April 2015.
The current list of Participating Jurisdictions for automatic exchange under both the CRS and the DAC can be found at.