The OECD Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) on 21 November 2024 published nine new peer review reports on transparency and exchange of information on request (EOIR), six of which combine an assessment of the legal framework and the implementation of the standard in practice.

The overall ratings issued for these jurisdictions vary from “Compliant” for Azerbaijan, to “Largely Compliant” for Bosnia and Herzegovina, Colombia, Senegal and Uganda and “Partially Compliant” for Montenegro.

The remaining three reports are limited to an assessment of the legal and regulatory framework for Grenada, Guyana and Rwanda, jurisdictions with limited practice of EOIR. Their frameworks were determined to be sufficient to move to the second phase of the review process, on the implementation in practice, due to take place in 2027, at the latest.

The new reports were approved by the Global Forum’s dedicated Peer Review Group in October 2024 and subsequently adopted by the Global Forum members. To date, 124 jurisdictions have been fully reviewed in the second round of EOIR peer reviews, which started in 2016, and the ratings assigned are generally positive, with 89% of the jurisdictions deemed “Compliant” or “Largely Compliant” with the standard, 9.5% assessed as “Partially Compliant”, and only 1.5% as “Non-Compliant”.

Jurisdiction-specific findings and recommendations include:

Azerbaijan has improved its compliance with the EOIR standard since its last peer review report published in 2016. It has strengthened the availability of accounting records and expanded tax authorities’ powers to access all necessary information. The authorities also enhanced their oversight of legal ownership information and ensured that no bearer shares are in circulation. While Azerbaijan has addressed all deficiencies identified in its previous peer review through these improvements, new issues were identified regarding the legal framework, specifically on the availability of beneficial ownership information for all relevant entities and arrangements that have no ongoing relationship with a person subject to anti-money laundering obligations. Complete legal ownership information is also not yet fully available in situations involving nominees or similar arrangements. Despite these remaining gaps, the Global Forum has determined Azerbaijan to be overall “Compliant” with the EOIR standard. Access the report

Bosnia and Herzegovina joined the Global Forum in 2018 and underwent its first review to assess compliance with the EOIR standard. The function of exchanging information is carried out by the competent authority of each relevant sub-state level, i.e. the Federation of Bosnia and Herzegovina, the Republic of Srpska and the District of Brcko, and all these competent authorities performed well to effectively provide information to their partners in a timely manner. Improvements remain nevertheless needed, both on legal and implementation-specific aspects, concerning the availability of the legal ownership and accounting information for companies with long-lasting non-compliance with tax obligations or without apparent economic activity. Shortcomings were also identified in the extent of beneficial ownership requirements and supervision. Further, the retention period of relevant records is not always ensured in practice once the entities are dissolved. The report also highlights the need for clarifications to effectively access beneficial ownership information and information held by lawyers. Moreover, Bosnia and Herzegovina needs to address gaps in respect of the extent of disclosure of the exchanged information to information holders and non-tax authorities. Overall, Bosnia and Herzegovina was rated “Largely Compliant” with the EOIR standard. Access the report

Colombia has made good progress since its first EOIR peer review report released in 2015. It has addressed recommendations and put in place an exchange of information (EOI) unit and processes for the management of EOI requests. To ensure the availability of up-to-date beneficial ownership information in line with the standard, Colombia has established a beneficial ownership register, which is maintained by the tax authority. As the register is new, Colombia should monitor its implementation and put in place a supervision system to ensure the data is of the expected quality and available for all relevant entities and arrangements. Other recommendations relate to the supervision and enforcement to be enhanced, to ensure the availability of legal, beneficial and accounting information for all entities, including those which are currently non-compliant with registration and filing requirements. The 2024 peer review rates Colombia as “Largely Compliant” with the EOIR standard. Access the report

Grenada’s peer review only assesses its legal and regulatory framework (Phase 1), as Grenada does not yet have sufficient EOIR experience to enable a meaningful evaluation of its practices relating to EOIR at this stage. The review concludes that, while Grenada has taken important steps towards increased transparency, improvements are required in several areas in respect of the availability, access and exchange of information. One of the key issues identified in its previous peer review published in 2014 was the availability of ownership and accounting information of international (offshore) entities and arrangements. Since then, Grenada has repealed the legal regime for international entities and arrangements. There remain, nevertheless, concerns regarding the availability of full ownership information for domestic companies. While Grenada has adopted a multi-pronged approach to implement the standard’s requirements on the availability of beneficial ownership information, deficits remain in the methods of identification of beneficial owners, as well as in the system governing companies’ beneficial ownership reporting obligations. Gaps are also noted in the legislative framework, regarding the availability of accounting records for legal entities and arrangements after they cease to exist, and there is limited information available to conclude that rights and safeguards of taxpayers will be compatible with effective exchange of information. The restrictions on the use of exchanged information by partner jurisdictions are inconsistent with the standard. The assessment of Grenada’s practical implementation of the legal framework (Phase 2 review) will be organised at a later date and launched in June 2027 at the latest. Access the report

Guyana joined the Global Forum in 2016 and was reviewed for the first time, on its legal and regulatory framework for EOIR (Phase 1) only, since it has not yet attained sufficient experience to enable a meaningful evaluation of its practice of EOIR. The peer review report concludes that Guyana’s legal and regulatory framework is generally in place to ensure the availability of legal and beneficial ownership, accounting and banking information, through a combination of commercial, tax, anti money laundering and banking laws. However, some areas for improvement remain, e.g. the availability of complete, and up-to-date legal and beneficial ownership information on all legal entities and arrangements is not yet ensured. Moreover, there are no obligations in place to ensure the availability of information, when companies, partnerships, and other entities, including banks, are dissolved or liquidated. Lastly, Guyana has a relatively small network of EOI relationships, some of which do not allow for effective exchange of information. The practical implementation of the legal and regulatory framework will be reviewed, and an overall rating assigned, in a Phase 2 review that will take place as soon as Guyana has gained sufficient experience in EOI, and in any case, no later than June 2027. Access the report

Montenegro joined the Global Forum in 2018 and was reviewed for the first time against the EOIR standard. The resulting report notes that the availability of legal ownership and identity information for relevant legal persons and arrangements is ensured through registration with public authorities. Beneficial ownership information should be available through the Anti-Money Laundering requirements, as well as through the national register of beneficial owners. However, despite recent advances, this register is still not fully populated and supervisory measures must be strengthened. In addition, deficiencies in the availability and timely access to accounting records and underlying documentation may undermine compliance with the EOIR standard. The report recommends enhancing supervisory and enforcement measures in this area, particularly in relation to companies failing to meet tax reporting obligations. Montenegro has a wide network of exchange relationships and has responded to practically all requests effectively. Nevertheless, the report identifies certain areas for improvement, including in the organisational processes for processing requests and measures seeking to ensure the confidentiality of exchanged information. Overall, Montenegro has been rated as “Partially Compliant” with the EOIR standard. Access the report

Rwanda joined the Global Forum in 2017 and was reviewed for the first time, only on its legal and regulatory framework for EOIR (Phase 1), having not yet attained sufficient EOIR experience to enable a meaningful evaluation of its practices relating to EOIR. The peer review report concluded that Rwanda’s legal and regulatory framework is in place to ensure the availability of legal and beneficial ownership information, as well as accounting information. The only recommendation issued pertains to ensuring that beneficial ownership information on bank accounts is always up to date to meet the standard. Rwanda has the necessary access powers in place to collect information requested by peers and its network of EOI instruments covers all relevant partners and meet the standard. The practical implementation of the legal and regulatory framework will be reviewed, and an overall rating assigned, in a Phase 2 review that will take place as soon as Rwanda attains sufficient experience in exchange of information, but in any case, not later than December 2027. Access the report

Senegal maintains the “Largely Compliant” overall rating assigned in its first-round review report published in 2016. The latest peer review report highlights progress made by the country to ensure the availability of beneficial ownership information, including through the establishment of a central register of beneficial owners managed by the tax administration. However, this central register is not yet fully populated and Senegal should therefore ensure that all relevant entities comply with their obligations to report beneficial ownership information. It should also ensure that accounting information of all relevant entities is always retained for at least five years after an entity cease to exist. Although Senegal adequately monitors tax compliance, it should address the risk of non-availability of accounting information from entities not registered with the tax administration and from inactive companies. The supervision of the availability of banking and beneficial ownership information on bank accounts should equally be strengthened. Furthermore, while Senegal has adequate access powers, its authorities have not used alternative available sources of information when facing difficulties in obtaining it from the concerned companies. Finally, the timeliness of responses to EOI partners’ requests has deteriorated over the last few years, which should be remedied. Access the report (version française)

Uganda was rated “Largely Compliant” with the EOIR standard in its previous peer review report published in 2016. It has taken several steps since then to improve its legal framework and align better with the EOIR standard, including by outlawing the possibility of issuing warrants to bearer, by setting up beneficial ownership registers, and by taking steps for the practical implementation of striking off the register companies that have been non-compliant with the filing of annual returns. However, further changes are required in the legal framework for always ensuring the availability of legal and beneficial ownership, accounting records and banking information, and, most importantly, a comprehensive and effective supervision programme must be put in place. In terms of actual exchange of information, the timeliness of responding to partners’ requests has deteriorated compared to the situation assessed in the 2016 report, and Uganda is thus encouraged to address this weakness.

The 2024 peer review report concludes that Uganda continues to be rated “Largely Compliant” with the EOIR standard. Access the report.