Recital 45

(45)The requirements for third-country entities with access to the internal market should be aligned to the standards laid down in Directive (EU) 2015/849 of the European Parliament and of the Council ²² . They should also be aligned to the standards set out in the common action undertaken by the Member States as regards non-cooperative jurisdictions for tax purposes, reflected in the Council conclusions on the revised EU list of non-cooperative jurisdictions for tax purposes. In particular, non-EU AIFs, non-EU AIFMs that are active in individual Member States and depositaries established in a third country should not be located in a high-risk third country pursuant to Directive (EU) 2015/849, nor in a third country that is deemed non-cooperative in tax matters, subject in certain cases to a grace period where a country is later identified as a high-risk third country pursuant to that Directive or is added to the EU list of non-cooperative jurisdictions for tax purposes. The requirements should also ensure the appropriate and effective exchange of information in tax matters in line with international standards such as those laid down in Article 26 of the OECD Model Tax Convention on Income and on Capital.