Tax Treaty Case Law around the Globe 2014

S. 355Chapter 36 Portugal: Right To Be Notified in Requested State

João Félix Pinto Nogueira

36.1. Introduction

Exchange of information has undergone a small revolution in the last years. In less than a decade, we moved from a system where privacy and secrecy seemed insurmountable to an era where automatic exchange of information for tax matters is even proclaimed as the new international standard.

A lot has been done in terms of what is usually known as the mutual agreement procedure (MAP). The European Union has revised its mutual assistance directives on administrative cooperation (Eol directives), tax collection and, more recently, the Savings Directive.

Within the OECD, besides the changes on article 26 (both in the OECD Model and the Commentary), extensive work has been done in the framework of the Global Forum (namely with the identification of the relevant criteria and the elaboration of the peer review reports) enabling the checking of not only formal but also substantive adherence to the new internationally agreed standards on transparency.

Worldwide, new information and communication technologies (ICT) systems were developed in order to ensure that the requests effectively S. 356arrive at...