Exchange of Information for Tax Purposes

1. S. 465Introduction

One of the consequences of globalization is the increased mobility of persons, goods, services and capital, thereby promoting worldwide economic and social development. This mobility implies cross-border transactions and movements that have tax consequences, especially when one considers that most states tax on a worldwide basis. In contrast, the sovereignty of states presents itself as a barrier to the assessment and collection of taxes.

Therefore, mutual assistance between states is becoming more and more important for tax authorities in order to assess the taxpayer’s situations correctly, to reach tax efficiency and to combat tax evasion and tax fraud, with the exchange of information the main tool to achieve this. Exchange of information can be done by different methods. Depending on the information, its availability and the need for it, there is an appropriate form that can or must be used by the states.

According to the model tax conventions and agreements, the main forms are exchange of information on request (on an individual basis or by group requests), spontaneous and automatic exchange of information. Moreover, other forms of administrative cooperation exis...