It appears that the Netherlands had signed the CbC MCAA on behalf of Bonaire, Saint Eustatius and Saba (the BES Islands). The OECD exchange relationship page now includes the BES Islands as having activated 25 automatic CbC exchange relationships under the MCAA.
Currently there is no CbC implementing legislation in BES Islands. Theoretically, therefore, exchange is possible because the Netherlands has signed on behalf of the BES Islands. In practice, however, no exchange can occur until CbC…