The OECD-Model-Convention and its Update 2014

I. S. 148Introduction

With the globalization and digitalization of the economy, tax avoidance and evasion schemes are becoming increasingly sophisticated and complex, and represent a serious challenge for domestic tax legislatures and administrations all over the world. In this interconnected environment, policymakers and tax authorities are becoming more and more aware of the fact that such international problems require coordinated solutions. Among the various international tools that have been developed and are currently used to counter cross-border tax evasion, one of the most significant is the exchange of tax information.

The first (truly) international instrument in the area of exchange of tax information dates back to the 1920s, but the matter has recently become a focal point of attention for several international organizations. It has also been the subject of countless debates within the academic tax community and even, in part thanks to unusually intense media coverage, among the worldwide public. Exchange of tax information is the subject of article 26 of the OECD Model Tax Convention on Income and Capital (OECD Model), and the issue has also been addressed in other contexts by...