Exchange of information

Exchange of Information is an umbrella term which refers to international co-operation in the field of taxation through the exchange of information on taxpayers between tax authorities.

International exchange of information rules shares many similarities with domestic tax information reporting, such as the United States' Form 1099 regime. However, rules are set on an international level; in recent years exchange of information efforts have been led by the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes.

There are 3 types of exchange of tax information which are currently in use:

  1. Exchange Of Information on Request (EOIR) - Tax treaties and tax information exchange agreements generally provide for tax authorities to request information in relation to the assessment, collection or prosecution of tax related issues. The OECD Global Forum conduct peer reviews on compliance with EOIR standards.
  2. Spontaneous Exchange of Information (SEI) - Certain international agreements provide for tax authorities to exchange information spontaneously where they discover something which may affect the tax payable in another country. For example, the EU's Directive on Administrative Co-operation in tax matters provides for spontaneous exchange of information.
  3. Automatic Exchange of Information (AEOI) - Since 2014, the OECD has promoted the automatic exchange of information between countries under the Common Reporting Standard (CRS). The US imposed similar reporting obligations through the Foreign Account Tax Compliance Act (FATCA) provisions.

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