Information Exchange Agreements (TIEA´s)

Iceland has concluded a total of 44 bilateral Tax Information Exchange Agreements (TIEA´s). Drafting of these agreements was based on the OECD TIEA model and the work was carried out by a Nordic Steering Group in the years 2008-2015. Tax authorities can request information in tax matters in accordance with the TIEA, which can be of significance for the assessment and enforcement of income tax.

In May 2015. an agreement was signed with the US government on the exchange of information on income and financial assets of taxable parties by the tax authorities in the contracting states. The agreement complies with the Foreign Account Tax Compliance Act (FATCA) adopted in the United States in 2010. The agreement requires tax authorities to collect information on the income and assets of all taxable persons from specifically designated financial institutions and send that information annually to the opposite contracting party. The first information exchange by Iceland based on FATCA took place in September 2015.

OECD developed the Common Reporting Standard (CRS), a new harmonized standard of financial information exchange, based on the Multilateral Convention on Administrative Assistance in tax Matters(Council of Europe/OECD). Iceland signed an agreement to implement the provisions of the standard in the autumn of 2015 and at present over 100 states have committed themselves to exchange financial information. The CRS out the financial account information to be exchanged, the financial institutions required to report, the different types of accounts and taxpayers covered, as well as common due diligence procedures to be followed by financial institutions. The first exchange of information on the basis of the standard was in September 2017 for the year 2016. Iceland amended Art. 92 of the Income Tax Act, No. 90/2003 in order to fully comply with international obligations for exchange of information in the field of taxation. See regulation no. 1240/2015, 1231/2016 and 940/2017, on the implementation of customer due diligence procedures

CbC reporting is part of the (BEPS) Action Plan and is one of the four BEPS minimum standards. The main purpose is to enhance transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks.  Iceland signed the Multilateral Competent Authority Agreement in May 2016 which was transposed into to the Income tax Act as Art. 4 of Act No. 112/2016. Iceland has signed a similar agreement with the US government for the submission of CbC reports.

The first exchange of CbC reports by Iceland will be in September 2018 for the year 2017.