The following Private Client guidance note provides comprehensive and up to date legal information covering:
This Practice Note provides an introduction to the Organisation for Economic Co-operation and Development (OECD)’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM).
For guidance on Tax Information Exchange Agreements (TIEAs), see Practice Note: Tax Information Exchange Agreements.
For an introduction to the automatic exchange of information, including the Foreign Account Tax Compliance Act and the Common Reporting Standard (CRS), see: Offshore tax evasion—overview.
The MAATM was first developed in 1988 by the OECD and the Council of Europe. As international trade barriers were reduced and capital became more mobile it was recognised that co-ordinated effort between states was necessary to combat tax avoidance and tax evasion on an international level. The MAATM provides for a single legal basis for bilateral and multilateral cooperation and allows for extensive forms of cooperation between competent authorities on a wide range of taxes.
The MAATM provides for the exchange of information on request, spontaneous exchange of information as well as automatic exchange of information.
In 2002 the OECD also published a model Agreement (the model Agreement) on Exchange of Information on Tax Matters. Under the model Agreement, exchange of information is by request only.
Exchange of information by request became the recognised standard of international tax transparency and cooperation in 2009 when a jurisdiction was deemed cooperative by the OECD if it had
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