MODEL AGREEMENT ON EXCHANGE OF INFORMATION IN TAX MATTERS (Model TIEA)
The purpose of this Agreement is to promote international co-operation in tax matters through exchange of information. It was developed by the OECD Global Forum Working Group on Effective Exchange of Information.
The Agreement grew out of the work undertaken by the OECD to address harmful tax practices. The lack of effective exchange of information is one of the key criteria in determining harmful tax practices. The Agreement represents the standard of effective exchange of information for the purposes of the OECD’s initiative on harmful tax practices.
This Agreement, which was released in April 2002, is not a binding instrument but contains two models for bilateral agreements. A large number of bilateral agreements have been based on this Agreement (see below).
In June 2015, the OECD Committee on Fiscal Affairs (CFA) approved a Model Protocol to the Agreement. The Model Protocol may be used by jurisdictions, in case they want to extend the scope of their existing TIEAs to also cover the automatic and/or spontaneous exchange of information.
In doing so, jurisdictions are then able to base a bilateral competent authority agreement for the purpose of putting in place the automatic exchange of information in accordance with the Common Reporting Standard or the automatic exchange of Country-by-Country Reports on a TIEA, in particular in cases where it is not (yet) possible to automatically exchange information under a relevant Multilateral Competent Authority Agreement.
Jurisdictions may also choose to use the wording of the Articles of the Model Protocol in case they want to include the automatic and spontaneous exchange of information provisions in a new TIEA.
MODEL TEMPLATE FOR REQUESTS OF INFORMATION
A Model Template for requests of information under TIEAs has been designed to assist competent authorities of TIEA partners in making requests for information. It is available in English and French as well as Spanish, German, Italian, Japanese, Korean and Turkish.
Recent bilateral agreements (by date of signature)
Also see TIEAs signed by Jurisdiction and TIEAs signed by individual jurisdiction