Exchange of Information for Tax Purposes

1. S. 485Introduction

The OECD, along with the Global Forum, has throughout the years been the organization taking the initiative of developing practical ways for the reciprocal supply of information between contracting states, with consideration for the increasing internationalization of economic relations. Therefore, the OECD has also tried to foresee how nowadays governments should handle exchange of information, and has set out various efficient and cooperative ways of achieving international tax cooperation regarding exchange of information. Because of the increasing necessity to fight tax evasion, and to counteract misconduct in the tax environment, among other objectives, the OECD has recently updated Article 26 OECD Model and its Commentary, by including a new way of exchanging information, which is the exchange of information through group requests. It is important to say that the 2012 update to Article 26 OECD Model reflects a consensus of all OECD member states. No country has made any kind of observation to that new version of Article 26 OECD Model and its Commentary.

Exchange of information through group requests was also intensively discussed at the level of the Global Forum. The OECD Global Forum Working Group on Effective Exchange of Information developed previously the TIEA Model, which was published in 2002 with the purpose of promoting international co-operation in tax matters through exchange of information.