This article contains a summary of a technical presentation given on 7 September 2016 to the independent EU data protection body established under article 29 of the EU data protection directive (‘Article 29 Working Party’ a.k.a. ‘WP29’). Like numerous other European privacy and data protection bodies, WP29 raised concerns in the past about the proportionality of the Common Reporting Standard (CRS).
The scope of the presentation was to illustrate the actual impact of the CRS based on practical examples analysed in the light of general tax law principles. A similar presentation was made to the Council of Europe’s Bureau of the Consultative Committee of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data in June 2016. (The Council of Europe is the platform used by 103 countries to implement the CRS on a multilateral basis.)
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