Exchange of Information for Tax Purposes

1. S. 155Introduction

1.1. TIEA Model

The Model Agreement on Exchange of Information on Tax Matters (TIEA Model) and its Commentary (TIEA Model Commentary) were published by the Organization for Economic Cooperation and Development (OECD) in 2002. The TIEA Model was the first instrument that defined the OECD standard of exchange of information and transparency (the OECD standard) with the objective of facilitating exchange of information between the parties to the TIEA. Today, the OECD standard is also reflected in Article 26 OECD Model Tax Convention on Income and on Capital (OECD Model) and its Commentary (OECD Model Commentary) as well as incorporated in the United Nations Model Tax Convention (UN Model), the Council of Europe/OECD Convention on Mutual Administrative Assistance in Tax Matters (CoE/OECD Convention) and European Union (EU) law.

The TIEA Model is a non-binding instrument available in both a bilateral and a multilateral version that can be used as a basis for the treaties negotiated by the relevant countries. The multilateral TIEA Model, however, has not yet been implemented in practice. The reason for this might be the existence of the multilateral CoE/OECD Convention that ...