OECD updates Model Tax Convention to Extend Information Requests to Groups of Taxpayers
The OECD has updated Article 26 of the OECD Model Tax Convention to allow tax authorities ask for information on a group of taxpayers, without naming them individually, provided the request is not a ‘fishing expedition’. Article 26 sets out the international standard on exchange of information, where the information is “foreseeably relevant” for the administration of the taxes of the requesting party, regardless of bank secrecy and a domestic tax interest.
According to the OECD, the new Article 26 facilitates exchange of tax information among law enforcement agencies to fight tax crimes and other criminal activities more effectively and all OECD countries have endorsed this latest update.