Tax Information Exchange Agreements
Tax Information Exchange Agreements

The following Private Client guidance note provides comprehensive and up to date legal information covering:

  • Tax Information Exchange Agreements
  • What is a TIEA?
  • TIEAs entered into by the UK
  • The OECD's model Agreement on Exchange of Information on Tax Matters

This Practice Note provides a brief introduction to Tax Information Exchange Agreements (TIEAs).

For guidance on the OECD's Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Multilateral Convention), see Practice Note: The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM).

For an introduction to the automatic exchange of information, including The Foreign Account Tax Compliance Act (known as FATCA) and the Common Reporting Standard (the CRS), see: Offshore tax evasion—overview.

What is a TIEA?

A TIEA is a bilateral agreement by which jurisdictions agree to co-operate in tax matters through the exchange of information.

Most TIEAs are based on the OECD's model Agreement on Exchange of Information on Tax Matters (the model Agreement) which was published in 2002.

Under the model Agreement, exchange of information is by request only (as opposed to automatic or spontaneous information exchange) and each TIEA sets out guidelines and criteria by which the requesting party must submit its request for information. The requesting party may only request information that is foreseeably relevant to the administration and enforcement of its laws. It may not engage in fishing expeditions or request information that is unlikely to be relevant to the tax affairs of a specific taxpayer.

Exchange of information by request as provided by the model Agreement became the recognised standard of international tax transparency and cooperation in