International Exchange of Information in Tax Matters

International Exchange of Information in Tax Matters

Towards Global Transparency

Xavier Oberson

Following the financial crisis of 2008 and various scandals around the world there has been a global movement towards the international exchange of information and greater transparency. This book provides a comprehensive overview of the main developments, the structure and content of the various existing instruments and models (such as double taxation treaties, TIEA, the multinational convention from the OECD, the European Directives, FATCA and the Swiss Rubik model), and also the new standard toward automatic exchange of information. Xavier Oberson's analysis highlights their interactions and complexities. He concludes by discussing the position and the rights of taxpayers.

Chapter 2: Historical development of international exchange of information rules

Xavier Oberson

Subjects: law - academic, commercial law, private international law, tax law and fiscal policy


Chapter 2 is devoted to the historical developments of international exchange of information in tax matters. It starts with the first model of double tax convention (DTC), which can be traced back to the work of the League of Nations, in 1920, and then moves on to the OECD Models DTC, including the initiative against harmful tax competition of 1998. The developments at the EU level are then described. Finally, after the so-called ‘big bang’ of March 2009, representing a major change in favour of global exchange of information, the paths leading, notably after 2013, towards automatic exchange of information as the new global standard are analysed.

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