Model Protocol for the Purpose of Allowing the Automatic and Spontaneous Exchange of Information

As the Multilateral Convention is now the most comprehensive and wide-ranging legal instrument for internationally exchanging information, it is expected that jurisdictions would in most cases choose to put in place the exchange of information, including under the Standard for Automatic Exchange of Financial Account Information in Tax Matters (the “Standard”), on the basis of the Multilateral Convention. There may, however, be instances where jurisdictions wish to implement the automatic and the spontaneous exchange of information on the basis of a TIEA (e.g. the exchange of information with dependent and associated territories or where a developing jurisdiction and a developed jurisdiction wish to put in place the automatic exchange of information). As the current Model TIEA does not provide for such forms of exchange, and most of the TIEAs currently in place reflect this approach, appropriate model wording for allowing the automatic and/or spontaneous exchange of information under a TIEA in these instances is herewith made available.