Trusted expertise across the complete tax information exchange lifecycle
3Rock provides specialist advisory services to government tax administrations and competent authorities, helping them navigate the complex path from implementation to review.
Who oversees the implementation of tax information exchange frameworks?
The Organization for Economic Cooperation and Development (OECD) through the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) is the international body responsible for monitoring, reviewing and assisting jurisdictions to implement international standards.
International tax transparency is built on a simple principle: that tax authorities should be able to access the information they need to ensure their residents are meeting their obligations, regardless of where assets are held or income is earned. Ending the era of bank secrecy and cross-border tax evasion requires coordinated global action - and that coordination is the mandate of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes.
The G20's mandate to the OECD following the 2008 financial crisis was straightforward: create global standards that make it significantly harder to hide assets offshore. The result was a suite of interlocking frameworks - EOIR, CRS, FATCA, and now CARF - each addressing a different dimension of the same problem. These are not voluntary guidelines; they carry real consequences for jurisdictions that fail to implement them effectively, including reputational damage, financial sector restrictions, and placement on EU list of non-cooperative jurisdictions for tax purposes.
3Rock's founding team has worked directly within this system — as assessors, as implementing authorities, and as advisors — giving us an operational understanding of these frameworks that no external observer can replicate.
Automatic Exchange of Information (AEOI)
Exchange of Information on Request (EOIR)
[Insert text from EOIR page]
What are some common implementation pitfalls countries should be aware of?
Gaps in the legal framework
Under the review of EOIR and AEOI, jurisdictions legislative implementation is assessed in line with effectiveness. Significant or fundamental gaps in the legal framework may impact the implementation of the standard in that jurisdiction, which may impact its rating in a peer review.
Operational resource constraints
A jurisdiction must implement human and IT resources that are adequate and appropriate for that jurisdiction in the context of its financial sector. The approach taken must balance resources on the ground and IT functionality, and must be defensible under review by an assessment team.
Lack of compliance verification activities
A key aspect of demonstrating a framework has been implemented effectively is regularly carrying out compliance verification activities - a balance of thematic and comprehensive - and deterring non-compliance through the application of penalties, including monetary fines.
3Rock’s technical expertise and hands-on experience in both the implementation and peer review process ensures holistic top-to-bottom support, designed to avoid common pitfalls and strengthen ratings .
Poor documentation of operational strategies and guidance material
During a peer review, the assessment team will expect a jurisdictions’ risk assessment, compliance strategy, and internal policies to be documented and periodically reviewed. Many jurisdictions either don’t have documentation, or they do but it’s fragmented and outdated.
OECD Peer Reviews
What are OECD peer reviews and why are they important?
OECD peer reviews are a system of jurisdictions holding each other accountable for implementing international tax transparency frameworks. These structured assessments include a review of a jurisdiction’s legal structure, ensuring internal policies and procedures are well documented, verifying that compliance and enforcement actions have a deterrent effect and promote a ‘culture of compliance’, and ensuring that data transmitted to exchange partners is complete and accurate.
The OECD peer reviews, such as the second round of Automatic Exchange of Information (AEOI) effectiveness reviews, is carried out by the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) with the support of a dedicated working group of peer jurisdictions - the AEOI Peer Review Group (APRG). These reviews are carried out simultaneously across 100+ jurisdictions, and include completion of detailed questionnaires, reviews of peer input provided on exchange statistics, an onsite visit by an AEOI Assessment Team, and a final report with a rating agreed by the OECD Global Forum and APRG.
The outcome of these reviews matter because they influence reputation, financial credibility, and whether global systems like tax transparency and anti-crime frameworks actually work in practice.
How is a jurisdiction’s rating determined?
Ratings are determined through a structured deliberative process involving the assessment team, the relevant peer review group (APRG for AEOI, PRMG for EOIR), and ultimately the Global Forum membership. Draft reports are shared with the reviewed jurisdiction before finalisation, and each jurisdiction has an opportunity to respond to findings, provide clarifications, and make formal interventions before the rating is agreed and the report published. The process is rigorous precisely because the published rating carries real consequences.
AEOI & EOIR Ratings Scale
Compliant (C): No material deficiencies.
Largely Compliant (LC): Material deficiencies that are likely to have limited impact.
Partially Compliant (PC): Material deficiencies with significant impact.
Non-Compliant (NC): Material deficiencies with fundamental impact.
Global Forum Review Milestones
Phase 1 Review: High-level initial review of AEOI/EOIR framework implementation. This desk-based review includes questionnaires and engagement with an OECD Assessment Team, but no onsite visit is required in phase 1. The report, and rating, is then published by the OECD Global Forum.
Phase 2 Review: Comprehensive in-depth review of AEOI or EOIR framework implementation. Includes detailed questionnaires, peer input on exchange statistics and data quality, an onsite visit by a Global Forum assessment team, and a final published report with a rating agreed by the Global Forum membership.
Ongoing Enhanced Review: Following the end of the second round of reviews (e.g. EOIR), ongoing monitoring is carried out by the Global Forum on key horizontal issues to prevent implementation backsliding.
Reassessment of Rating: If a jurisdiction receives a weak rating (PC or below), it may request reassessment once it can demonstrate progress has been made.
What is the impact of a negative OECD peer review?
The end result jurisdictions wants to achieve is a rating of Largely Compliant or higher, as a weak rating can have several strategic implications and in particular, it can affect and lead to the following outcomes:
Reputational risk and heightened scrutiny: Risk of being added to the list of non-cooperative jurisdiction by the European Union, leading to increased monitoring, follow-up reviews, and adverse assessments by international bodies.
Increased restrictions by partner jurisdictions: Peer jurisdictions may impose stricter compliance requirements or enhanced due diligence on transactions.
Financial sector de-risking: Global banks may limit or review relationships with Financial Institutions, affecting cross-border connectivity.
Higher remediation burden: Additional effort and resources required to address identified gaps and strengthen systems.
How does 3Rock support jurisdictions’ implementation efforts and enhance their ratings in OECD peer reviews?
AEOI Effectiveness Review
The peer review of the AEOI Standard is currently ongoing. 3Rock supports jurisdictions by ensuring the risk assessment process, compliance strategy, identification of the FI population, compliance verification and enforcement activities, and the data quality transmitted to exchange partners, in the context of that jurisdiction. Where a jurisdiction has been issued a weak rating (below Largely Compliant), 3Rock also provides assistance with the re-assessment process once implementation has improved.
FHTP Peer Review
The Forum on Harmful Tax Practices (FHTP) assess the implementation of Substantial Activities requirements (i.e. Economic Substance) across all no or only nominal tax jurisdictions. Particular emphasis is being placed on verification activities, including onsite audits, of holding companies, classification issues surrounding Entities that claim to be out of scope of the requirements, and enforcement actions for identified non-compliance.
EOIR Peer Review
The EOIR process is the longest standing review process overseen by the OECD Global Forum. Currently in the third round of reviews, the Peer Review and Monitoring Group (PRMG) continues to asses deficiencies in legal frameworks, timeliness of responses to requesting jurisdictions, along with a number of other horizontal issues in the enhanced monitoring progress. If your jurisdiction need assistance addressing gaps in beneficial ownership or accounting records, or have a backlog of requests - 3Rock can help.
CARF Legislative Assessment
Effectiveness reviews for the CARF have not yet started, but will likely mirror the review carried out of the CRS. At the early stages, however, jurisdictions will be able to have their exchange mechanisms in place, a legal framework that supports the collection and exchange of information, and have the necessary confidentiality and data safeguards in place to begin exchanging information in 2027.
Connect with 3Rock
Let’s start a discussion on the ways the 3Rock Consulting partners can help your jurisdiction effectively implement tax information exchange frameworks. Please complete the government-specific request form below, and a 3Rock advisory will respond within one business day.