THE OECD has updated Article 26 of
the OECD Model Tax Convention, which sets out the international standard on
exchange of information. The standard provides for information exchange on
request, where the information is “foreseeably relevant” for the administration
of the taxes of the requesting party, regardless of bank secrecy and a domestic
tax interest.
The update explicitly allows for group requests. This means
that tax authorities are able to ask for information on a group of taxpayers,
without naming them individually, as long as the request is not a 'fishing
expedition'. This update represents a step forward towards more transparency,
according to the OECD’s Centre for Tax Policy.
The new Article 26
facilitates exchange of tax information among law enforcement agencies to fight
tax crimes and other criminal activities more effectively. This is in line with
the Oslo Dialogue initiative launched by the OECD. All OECD countries have
endorsed this latest update.
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