The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM)
The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM)

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

  • The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM)
  • What is the history of the MAATM?
  • Which jurisdictions have signed the MAATM?
  • How is the MAATM implemented into domestic law?
  • MAATM—key provisions
  • Taxes covered by the MAATM
  • MAATM and assistance in information exchange
  • MAATM and assistance in the recovery of taxes
  • MAATM and confidentiality and protection of taxpayers' rights
  • Interaction between the MAATM and other information exchange instruments

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). Types of administrative assistance under MAATM range from the exchange of information, including automatic and spontaneous exchanges of information, to the recovery of foreign tax claims.

For an introduction to the CRS, see Practice Note: Automatic exchange of information—the Common Reporting Standard: a summary.

What is the history of the MAATM?

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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