Exchange of Information for Tax Purposes

1. S. 133Introduction

Business models adopted in the last decades have shown companies expanding their activities cross border. What in the past was a strategy reserved only to a limited class of companies – usually big multinational groups with power to invest abroad – has turned out to be feasible for smaller enterprises.

The presence of companies in foreign markets is a remarkable fact today. Their existence overseas takes very different shapes and lasts varying periods. A continuous form might occur, for instance, with the incorporation of an enduring permanent establishment, whereas a specific project may demand a company to render one service for only a very short period in time. There might be even cases in which a company moves its entire facilities and operations to other state, definitively leaving its country of origin.

In addition, individuals have never had such an ease of mobility, which is in big part a consequence of the flexibility countries have been providing for tourism, business and other activities. Concrete examples of such freedom that individuals find are the business they do abroad as sole entrepreneurs and retirement enjoyed in foreign countries.

As a result of the...