29/09/2021 - A workshop on the concept of foreseeable relevance targeted at tax officials involved in exchange of information (EOI) was organised by the Global Forum Secretariat. Held virtually on 28-29 September 2021, it was attended by 149 participants from 81 jurisdictions.

The workshop aimed at strengthening awareness and improving co-operation and mutual understanding of the concept of foreseeable relevance among participants. A particular focus was put on areas where the application of the concept can be discussed, e.g. transfer pricing requests and group requests. Through practical sessions under the guidance of the Secretariat, participants simulated the critical steps of an EOI request analysis, both in the role of requesting and requested jurisdiction.

The concept of foreseeable relevance is at the core of all forms of EOI. Supplying and receiving jurisdictions shall exchange such information as is foreseeably relevant to ensure the correct application of the provisions of international agreements between them, or of their domestic laws. This standard is intended to provide for EOI in tax matters to the widest possible extent and, at the same time, to clarify that jurisdictions are not at liberty to engage in “fishing expeditions”, or to request information that is unlikely to be relevant to the tax affairs of a given taxpayer.

Through its peer review process, the Global Forum analyses the concept of foreseeable relevance and its implementation in practice and issues recommendations where needed.