Towards Global Transparency
Chapter 3: Exchange of information under Double Taxation Conventions (DTC)
Chapter 3 focuses on exchange of information under DTC. Indeed, double taxation treaties, notably based on the OECD Models, remain as of today the main source of exchange of information in tax matters. This chapter covers the scope of a DTC (material, personal and tax covered), the competence and secrecy rules, and the various forms of exchange of information, including simultaneous tax examination and joint audits. The potential limits to the exchange, such as the principles of subsidiarity, the principle of reciprocity, trade or business secrets, or public policy, are then analysed. Special attention is also given to the derogation of Art. 26 par. 5 of the OECD Model, which, in particular, provides that banking secrecy is no longer a valid ground for refusal of the exchange of information.
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