The Global Forum on Transparency and Exchange of Information for Tax Purposes has published its sixth annual progress report on the Latin America Initiative, covering developments through 2025. The report, *Tax Transparency in Latin America 2026*, draws on survey responses from all 16 participating countries and sets out the most complete picture yet of how exchange of information (EOI) is being embedded in day-to-day tax enforcement across the region. The full report is available to download from the OECD website.
Background: the Latin America Initiative
Tax evasion costs Latin American economies an estimated 6.7% of regional GDP, according to figures from the UN Economic Commission for Latin America and the Caribbean. That figure provides the backdrop for the Latin America Initiative, which grew out of the Punta del Este Declaration signed in November 2018 by four founding countries on the sidelines of the Global Forum Plenary in Uruguay.
Fifteen countries are now signatories: Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, El Salvador, Guatemala, Honduras, Mexico, Panama, Paraguay, Peru and Uruguay. Bolivia participates as an observer. Six development partners support the Initiative: the Inter-American Centre of Tax Administrations, the Inter-American Development Bank, the International Finance Corporation, the Spanish Institute of Fiscal Studies, the Spanish Agency for International Development Cooperation, and the World Bank. Donors include Canada, the European Union, France, Germany, Ireland, Japan, the Netherlands, Norway, Spain, Sweden, Switzerland and the United Kingdom.
The Initiative operates under a one-year rotating Chair and Vice-Chair drawn from senior tax administration or ministry of finance officials. For 2025, the Chair was Adriana Gomes Rêgo of Brazil's Federal Revenue Service. For 2026, the Chair is Javier Franco Castillo, National Superintendent of Customs and Tax Administration of Peru, and the Vice-Chair is Gustavo González Amilivia, Director General of Revenues of Uruguay.
Work plan 2024–2026
The current three-year work plan rests on two pillars. The first, baseline actions, aims to ensure every member has a legal, organisational, and operational framework sufficient to benefit fully from EOI: a functioning EOI infrastructure, effective implementation of the international transparency standards, and trained officials. The second, complementary actions, is voluntary and covers additional forms of mutual administrative assistance, notably wider use of treaty-exchanged information, simultaneous tax examinations, and tax examinations abroad.
The baseline work covers eleven discrete activities across three clusters: exchange of information on request (EOIR), automatic exchange of information (AEOI) under the Common Reporting Standard (CRS) and the Crypto-Asset Reporting Framework (CARF), and knowledge tools and training. The complementary actions include the Wider Use Pilot Project and tools for simultaneous and cross-border examinations.
Revenue outcomes: EUR 29 billion since 2009
The headline number is substantial. Since 2009, Latin American members have identified at least EUR 29 billion in additional tax, interest, and penalties through EOI mechanisms and related voluntary disclosure programmes (VDPs). Of that total, EUR 4.9 billion is attributed to EOIR and offshore investigations; EUR 24.1 billion to CRS implementation and associated VDPs.
Latin America accounts for roughly 21% of the additional revenue identified globally by all 173 Global Forum members during the same period, a share that the report notes is probably understated because many countries have not yet built the internal monitoring systems needed to capture the full revenue impact.
In 2025 alone, the region identified at least EUR 577.6 million: EUR 34 million from EOIR and EUR 543.6 million from CRS data, the highest CRS-related figure ever recorded for the region. One member reported EOIR-related revenue for the first time. The 2025 figures represent deeper and more systematic integration of EOI into compliance work rather than a step-change in activity volumes.
Volumes and trajectory
In 2025, Latin American countries sent 691 EOIR requests and received 538, maintaining the region's long-standing position as a net sender. Overall volume fell by 33% compared with 2024, but the report is clear that this does not reflect reduced engagement. Prior peaks were driven by exceptional circumstances: data leaks that triggered mass investigations, a surge in CRS-led requests, and individual court proceedings that each generated more than 100 requests. Those factors were absent in 2025. Across the full 2009–2025 period, the underlying trend in requests sent is firmly upward.
More significant than absolute volume is the broadening of participation. Between 2009 and 2018, just four countries accounted for 95.5% of all outbound requests. Over the 2019–2025 period, eight countries account for 97.3%, and in 2025 alone ten countries represent 99.9% of requests sent. The concentration that characterised the Initiative's early years has substantially diminished.
Several countries recorded exceptional growth. Guatemala increased requests by 150% year on year in 2025 and by 2,400% relative to 2020. Peru's use of EOIR rose by 7,450% against 2020. Panama grew by 94% year on year and 933% against 2020. Ecuador and the Dominican Republic each recorded year-on-year rises exceeding 250%.
CRS as a trigger for EOIR
A structural shift is now visible in what prompts EOIR activity. On average, 31% of outbound requests between 2021 and 2025 originated from analysis of CRS data, rising to 37.1% in Peru, 31.8% in Argentina, and 26.7% in Ecuador in 2025. CRS data identifies offshore accounts whose balances appear disproportionate to declared income or where income appears undeclared; those findings then ground a foreseeably relevant request for further information. The two standards are functioning as an integrated system rather than parallel instruments.
Group requests
Group requests, under which information is sought about a class of taxpayers who are not individually identified, grew sharply. Between 2019 and 2023 only four group requests were made by the region; in 2024 and 2025 combined the total was 18. They have proved particularly effective in digital-economy cases, where individual identification is difficult and non-compliance operates at scale. Countries also used group requests in relation to cross-border digital VAT and regional trade invoice fraud.
An EOIR Model Strategy
In response to self-assessment findings that revealed weaknesses in early integration of EOIR into audit processes and in internal communication between EOI units and audit teams, members of the Initiative developed an EOIR Model Strategy. Eleven countries committed to conducting formal self-assessments of their EOIR frameworks as a first step towards national strategies. A Resolution by Heads of Tax Administrations to Maximise the Use of Exchange of Information on Request was endorsed at the 12th Initiative meeting in June 2025.
Country experiences in practice
The report contains detailed case studies from five jurisdictions, illustrating the practical mechanics of EOIR.
Guatemala. Guatemala's Superintendence of Tax Administration (SAT) identified EUR 22.5 million in additional revenue in 2024–2025 directly from information received through EOIR. A key case involved a foreign-based digital hospitality platform. SAT identified that declared income of platform operators was inconsistent with observed turnover, submitted an initial individual request that confirmed the discrepancy, then — because individual identification of all affected taxpayers was impracticable — submitted a group request. Significant inconsistencies were found in more than 85% of taxpayers examined. SAT also used EOIR to verify suspected fictitious invoicing in Central American regional trade, and to trace funds transferred from Guatemala to other jurisdictions to simulate transactions and evade domestic tax.
Peru. SUNAT's 2026–2030 Strategic Plan embeds EOIR as a formal strategic objective. It has established a dedicated Mutual Administrative Assistance Unit, incorporated an EOIR indicator into its tax compliance planning instrument, and promotes the use of CRS data to trigger requests. Outbound requests grew from 107 in 2023 to 136 in 2024 and 151 in 2025. In one CRS-driven case, SUNAT received data on a resident's offshore investments, identified undeclared foreign-source income, and — after exhausting domestic means — submitted an EOIR request that led to the filing of amended returns. SUNAT also submitted a group request covering more than 34,000 property owners who had earned rental income through a digital platform without declaring it, and is pursuing a parallel strategy on digital VAT compliance, resulting in 30 digital platforms registering for VAT with estimated annual revenues of EUR 84.6 million and estimated VAT contributions of EUR 15.2 million.
Paraguay. Paraguay's National Directorate of Tax Revenues (DNIT) identified a corporate taxpayer holding 85% of its liquid assets in an overseas bank account from which no income or expenses had been declared. After exhausting domestic channels and receiving a denial of bank records from the taxpayer, DNIT submitted an EOIR request grounded on tax-evasion prevention, compliance verification, and tax-base determination. The information received contradicted the taxpayer's account and revealed undeclared dividend distributions to shareholders. The resulting assessment was approximately EUR 1 million. This was the first time Paraguay identified revenue through EOIR.
Mexico. Mexico's SAT audited an individual with complex structures across two jurisdictions involving four entities and a legal arrangement, all reportedly subject to preferential tax regimes. SAT requested articles of association, tax residence information, annual returns, shareholder details, financial statements, and evidence of income and withholding. Country A confirmed that two of the entities were not tax-resident there and that income was taxed at partner level. Country B confirmed registration of the other two entities and provided incorporation documents. Based on the information, SAT identified multiple streams of omitted income, and the taxpayer regularised, yielding approximately EUR 7.2 million.
Ecuador. Ecuador's Internal Revenue Service (SRI) investigated an importer of agricultural inputs whose disclosed supplier was a related-party intermediary located in a MAAC jurisdiction, while the actual shipments originated from eight ports in other countries. The taxpayer provided no documentation of supplier transactions. SRI demonstrated foreseeable relevance through a description of the transfer-pricing triangulation used to inflate deductible costs and shift profits to a low-tax jurisdiction, sent nine requests (one to the intermediary's jurisdiction, eight to the ports of shipment), and identified non-deductible expenses exceeding EUR 5.1 million, resulting in an additional tax liability of approximately EUR 1.7 million.
Data received
Ten Latin American countries were exchanging CRS data by 2025, with Paraguay committed to commence in 2027. In 2025, those ten countries received data on more than 5 million foreign financial accounts with a combined value of EUR 463 billion, a record for the region. The value of accounts received has grown from EUR 40 billion in 2017 to EUR 463 billion in 2025; the number of accounts has grown from 0.1 million to 5.1 million over the same period.
Data matching and operational use
Automatic data-matching rates among countries that report them have improved from 20% in 2017 to 81% in 2025. The operational focus has shifted from receiving data to acting on it. By 2025, 100% of reporting CRS-active countries use CRS data for tax audits, 90% for risk assessment, 90% for tax recovery, 70% for taxpayer notification, and 10% for pre-filling of tax returns. All ten CRS-active countries signed the Addendum to the CRS Multilateral Competent Authority Agreement in 2025, enhancing the legal usability of received data.
Brazil became the first Latin American jurisdiction to use CRS data to pre-fill individual income tax returns, integrating offshore account information directly into the return form. Its High-Net-Worth Individual unit also assessed approximately EUR 441 million in tax credits relating to capital returned by offshore entities between 2021 and 2025, and EUR 61.2 million from trust distribution income by 2025. In 2025, Brazil identified further cases of substantial discrepancy between CRS-reported payments and declared income.
Peru's SUNAT set a 2025 revenue target of EUR 30.3 million from EOI-data-driven compliance actions. A preventive awareness campaign targeting nearly 15,000 individuals with foreign financial accounts produced a 21% increase in returns filed and a 77% increase in payments. Combined actions generated EUR 65.8 million, substantially exceeding the target.
Ecuador, through CRS data, enabled the regularisation of previously undeclared foreign assets totalling EUR 1,636 million and identified EUR 107 million in additional revenue attributable to CRS data and VDPs.
Uruguay's Directorate General of Taxation uses CRS data primarily for preventive outreach, communicating with taxpayers who have failed to file or submitted inconsistent information. CRS data is also used in income and wealth audits and is being integrated into risk analysis models under development.
A Working Group on the Effective Use of CRS Data was established at the June 2025 Initiative meeting to share regional experience and case studies and to refine two practical guides: the Step-by-Step Guide on cleansing and matching CRS data and the Guide on tax adjustments based on CRS data.
Infrastructure: strengths and gaps
Most Latin American members now have the core EOI infrastructure in place. Survey data from 16 countries shows that 100% have EOI manuals or procedures, 94% have a designated competent authority and a tracking tool, 88% have a dedicated EOI unit, and 94% have functional communication channels. However, only 19% have tools to assess the revenue impact of EOI, which explains why measured revenue figures are likely understated. Formalised arrangements (such as memoranda of understanding) with other domestic authorities exist in 38% of members, though this proportion is growing.
The region benefits from 2,090 bilateral EOI relationships, 79% of which are covered by the Convention on Mutual Administrative Assistance in Tax Matters (MAAC). The MAAC is the backbone of the regional network. Honduras, which signed the MAAC in 2022, has not yet ratified it; ratification would significantly expand its partner network. High-level visits to both Honduras and Bolivia in 2025 pressed forward their respective engagement with the international standards.
Peer review ratings and implementation gaps
More than 75% of Latin American jurisdictions now have satisfactory EOIR ratings from the Global Forum peer review process. Honduras completed the first phase of its EOIR peer review in 2025 and was assessed as having a legal framework generally in place. Ecuador received an "On-Track" rating in its initial CRS effectiveness peer review.
Remaining weaknesses centre on beneficial ownership. Supervision and enforcement of beneficial ownership rules are areas of persistent concern across multiple jurisdictions. On CRS, legal frameworks are largely in place, but practical implementation varies: risk-based oversight of financial institutions and identification of the full population of reportable entities remain uneven. A regional event on beneficial ownership in November 2025 examined the state of central ownership registers across the region, highlighting challenges around accessibility, interoperability, and the verification of data quality.
The Crypto-Asset Reporting Framework: preparing for 2027–2028
Six Latin American countries have formally committed to implementing the CARF: Brazil, Chile, and Colombia for first exchanges in 2027, and Costa Rica, Mexico, and Panama for 2028. Argentina has adhered to the Joint Statement on the CARF, which includes an intent to work towards transposing the Framework into domestic law and activating exchange agreements in time for 2027 exchanges, subject to legislative procedures. Globally, 76 member jurisdictions have committed to implementing the CARF by 2029. Capacity-building activities in 2025 focused on legal transposition and operational readiness, including a regional training event dedicated to CARF.
The Wider Use Pilot Project
A milestone was reached in 2025 with the creation of the Wider Use Task Force under the Pilot Project for the Wider Use of Treaty-Exchanged Information. The Task Force supports implementation of the Wider Use Multilateral Competent Authority Agreement, reports to the Latin America Initiative, and will contribute to the forthcoming five-year review of the project. Its 2026–2027 work plan focuses on developing operational arrangements for sharing treaty-exchanged information with non-tax authorities and producing a playbook of wider-use cases. The ambition is to use information exchanged under tax treaties to support the fight against corruption, money laundering, terrorist financing, and customs-related offences, consistent with the objectives of the Punta del Este Declaration.
Capacity building in 2025
The report records the following training and technical assistance outcomes for 2025:
- All 15 Latin American members received bilateral technical assistance.
- Over 1,600 officials from 17 countries attended 27 training and experience-sharing events; women represented more than 54% of participants.
- More than 3,000 officials from 16 countries completed Global Forum e-learning courses.
- Certified local trainers from the revamped Train the Trainer Programme delivered training to more than 800 officials at national level.
- Five women from five member countries participated in the Women Leaders in Tax Transparency Programme.
- 66 officials from 13 members participated in the Information Security Management (ISM) Network, and 75 officials from 13 countries attended the third edition of ISM Days.
- Several practical toolkits were released during the year, covering beneficial ownership, CRS data matching, and CRS-based tax adjustments.
Technical assistance in 2025 was concentrated on three priorities: closing gaps identified through EOIR and CRS peer reviews and preparing for upcoming reviews; aligning domestic legal frameworks with the 2023 amendments to the CRS and preparing for CARF; and embedding effective use of EOI into compliance strategy.
Governance milestones and Initiative meetings
The 12th Initiative meeting, held in Salvador de Bahia, Brazil on 3–4 June 2025, produced the Resolution by Heads of Tax Administrations, endorsed the CRS Working Group, commended the Wider Use Pilot, and appointed Peru and Uruguay to lead the Initiative in 2026. The statement of outcomes is published separately.
The 13th Initiative meeting took place on 1 December 2025 in New Delhi, alongside the 18th Global Forum Plenary. It reviewed self-assessment findings on EOIR, encouraged further capacity building to address shared challenges, and approved the Wider Use Task Force work plan for 2026. Its statement of outcomes is also available.
What practitioners should note
Several points in this report carry direct practical significance for advisers with Latin American clients.
First, the integration of CRS data and EOIR is now a well-established operational reality, not a theoretical risk. On average, nearly one in three outbound requests from CRS-active countries originates from CRS data analysis. Where a client holds undisclosed offshore accounts, the probability of detection has materially increased.
Second, group requests are becoming a significant enforcement tool, particularly in the digital economy. Clients deriving income from cross-border digital platforms, whether as operators or as hosts providing services through those platforms, are squarely within the scope of recent group request activity in Guatemala and Peru.
Third, transfer pricing cases are now routinely supported by EOIR. Ecuador's triangulation case demonstrates that tax authorities will seek information from multiple jurisdictions simultaneously, including ports of shipment, to test claimed supply-chain structures.
Fourth, CARF implementation is approaching. Chile and Colombia have committed to 2027 exchanges. Advisers with clients holding crypto-assets in or through Latin American jurisdictions should begin assessing the likely reporting consequences now.
Fifth, revenue from EOI is accelerating, not plateauing. The EUR 577.6 million identified in 2025 from CRS and EOIR combined is the highest annual figure recorded. The report explicitly notes that this still understates the true impact, because many countries have not yet built the monitoring infrastructure to capture EOI-related revenues fully.
The full report, which contains further country-by-country analysis, annexes on each member's progress, and the text of the Punta del Este Declaration, runs to more than 115 pages. The extracted text above covers chapters 1 through the opening of chapter 3; chapters 4 and 5 and the annexes contain additional detail not reproduced here.
Primary sources
- Tax Transparency in Latin America 2026 — full report (PDF)
- Punta del Este Declaration (PDF)
- Status of CRS commitments (PDF)
- Status of CARF commitments (PDF)
- 12th Initiative meeting — statement of outcomes (PDF)
- 13th Initiative meeting — statement of outcomes (PDF)
- Tax Transparency in Latin America 2025 — previous edition (PDF)