Tax Information Exchange Agreements (TIEAs)

Exchange of Information for Tax Purposes, Oliver-Christoph Günther/ Nicole Tüchler (Eds.), Linde Verlag Wien, ISBN 978-3-7073-2409-9, 2013

22 Pages Posted: 26 Aug 2015

See all articles by Marta Pankiv

Marta Pankiv

Vienna University of Economics and Business

Date Written: August 8, 2013

Abstract

The Model Agreement on Exchange of Information on Tax Matters (TIEA Model) and its Commentary (TIEA Model Commentary) were published by the Organization for Economic Cooperation and Development (OECD) in 2002. Today, the OECD standard is also reflected in Article 26 OECD Model Tax Convention on Income and on Capital (OECD Model) and its Commentary (OECD Model Commentary) as well as incorporated in the United Nations Model Tax Convention (UN Model), the Council of Europe/OECD Convention on Mutual Administrative Assistance in Tax Matters (the CoE/OECD Convention) and European Union (EU) law. The TIEA Model contains specific provisions regarding exchange of information on request, the possibility of declining a request for information, tax examinations abroad, and a confidentiality clause. In addition, it includes provisions of an administrative nature such as allocation of costs associated with the execution of TIEAs and language usage for making and responding to requests. This contribution gives an overview of the main provisions of the TIEA Model with the focus on its content, the specificity of the information request and the application of TIEAs in practice.

Keywords: TIEA, exchange of information, transfer pricing, tax

JEL Classification: T33, T34

Suggested Citation

Pankiv, Marta, Tax Information Exchange Agreements (TIEAs) (August 8, 2013). Exchange of Information for Tax Purposes, Oliver-Christoph Günther/ Nicole Tüchler (Eds.), Linde Verlag Wien, ISBN 978-3-7073-2409-9, 2013, Available at SSRN: https://ssrn.com/abstract=2648583

Marta Pankiv (Contact Author)

Vienna University of Economics and Business ( email )

Welthandelsplatz 1
Vienna, Wien 1020
Austria

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