As part of these agreements, information on financial accounts for the years 2014 to 2016 was exchanged. Subsequently, the United Kingdom and all crown dependencies and overseas territories adopted the Common Reporting Standard (SIR) for the exchange of information on financial accounts. Since 2017, the IRS has completely replaced these old automatic exchange of tax information agreements. A key element of the successful implementation of the IRS is the creation of an international framework for the automatic exchange of IRS information between legal systems. More than 95 legal systems have committed to the exchange of information within the IRS and, as noted above, exchanges between legal systems are generally based on the multilateral convention and the Multilateral Competent Authority IRS Convention (MCAA CRS), which is itself based on Article 6 (AIA) of the Multilateral Convention. In limited cases where it is not yet possible to rely on the multilateral convention and the IRS-MCAA to exchange information, legal systems can rely on bilateral agreements such as bilateral double taxation agreements (DBA) or tax information exchange agreements (TIEAs). As a result of the agreement between the United Kingdom and the United States on the automatic exchange of information, all dependence on the crown and overseas territories has entered into automatic agreements for the exchange of tax information with the United Kingdom. Implementation of UK agreements with crown dependencies to improve international tax compliance The catalyst for the agreements has been the U.S. Tax Compliance Accounts Act (FATCA). Each jurisdiction wanted to include an intergovernmental agreement (IGA) on the implementation of FATCA.
As the latter are considered international treaties, they would require the agreement of the United Kingdom. It was therefore agreed that equivalent information transmitted to the United States would be communicated to the United Kingdom. In the South African context, the AEOI was until recently linked to the information exchange process between South Africa (SA) and the United States. In 2013, the National Treasury and the South African Revenue Service (SARS) began negotiations with the U.S. Department of Finance to draft an intergovernmental agreement (IGA) on the U.S. Account Compliance Act (FATCA).