Exchange of Information for Tax Purposes

1. S. 17Introduction

In the last decades the globalization of economy, the growth of cross-border trades, the internationalization of companies and financial services, the computerization of banking and the increase of mobility opportunities for taxpayers have multiplied the chances for ‘international’ tax evasion and created new challenges for tax administrations all over the world. These phenomenon rendered unavoidable an always greater need for the exchange of tax information among tax authorities on two different levels: on the level of tax assessment (especially for multinational enterprises and taxpayers operating cross-border), and on the level of tax collection (the effective enforcement of measures at this level requires very high standards of co-operation among states).

The history of the international exchange of tax information began in the twenties and has quickly developed in the past decades together with globalization. The firsts traces of exchange of information tools are in some Draft Conventions issued by the League of Nations in the twenties, but the core are found in the several Model Conventions and Commentaries issued by the Organization for Economic Co-operation an...