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By Oliver R. Hoor *
On 17 July 2012, the OECD Council approved an update to Article 26 of the OECD Model Tax Convention (“OECD Model”) and its Commentary which set the international standard on exchange of information. This standard provides for information exchange on request where the information is “foreseeably relevant” for the administration of taxes of the requesting State. This article provides an overview of the most important changes to Article 26 of the OECD Model and its Commentary.
I. Introduction
In cross-border situations, the tax authorities of a Contracting State often depend on the co-operation of the tax authorities of the other Contracting State for the gathering of information necessary for the application of the...
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