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International Bureau of Fiscal Documentation
IBFD special monitor - Tax Information Sharing
15 November 2009
Since 1938, the International Bureau of Fiscal Documentation (IBFD) has documented the
progression of cross-border taxation. One of the more recent progressions has been the
developments in transparency and exchange of information regarding tax matters. Much of this
activity has been driven by governments’ desire to secure their tax bases during tough economic
times as well as the OECD’s advocacy of a threshold to distinguish between jurisdictions which have
implemented standards for information sharing and those which have not.1
Many States have addressed the new interest in bank secrecy through a multiple step approach.
States have created tough new legislation on offshore withholding, signed bilateral agreements to
allow cooperation between States, and, in some cases, initiated amnesty or voluntary disclosure
programs to encourage cooperation from account holders. The practical result has been the creation
of new legislation regarding information sharing, voluntary disclosure programs, and the mass
passage of tax information exchange agreements. Whether or not the era of bank secrecy is at an
end, the playing field has been permanently altered and a new set of rules is being quickly
implemented.
As an academic institute and curator of the world’s largest holding of international tax materials, the
IBFD has endeavoured to document these changes. The role of our researchers has been covering
and analyzing the passage of new information disclosure legislation as well as the corresponding
implementation of disclosure programs by State’s tax administrations. Our main documentary task,
however, was the worldwide collection of the various protocols, treaties, and information exchange
agreements.
Through the attached appendices, please find coverage of the changes that have taken place around
the world over the past two years. New legislation and cooperation is announced daily and we will
strive to keep our databases up to date.
In Appendix I, we present examples of legislation enacted by countries to curb tax secrecy and
offshore withholding. It will take several years to understand the economic consequences of these
laws and their effectiveness to encourage fiscal transparency. However, by capturing and
documenting these legislative changes now, they can be preserved and become part of the
foundation to more fully understand and implement effective legislative measures.
Appendix II includes highlights and descriptions of State’s voluntary disclosure programs. These
programs were designed to encourage immediate compliance before the passage of new legislation
1 See attached Jeffrey Owens “Moving Towards Better Transparency and Exchange of Information on Tax
Matters” Bulletin for International Taxation, November 2009
or stiffer penalties. As many of these programs begin to expire, we will be able to weigh the success
of different state’s programs and hopefully conclude which measures yielded more success.
Appendix III lists the Tax Information Exchange Agreements recently included in our database. A Tax
Information Exchange Agreements (TIEAs) is generally based on a model agreement developed by
the OECD Global Forum Working Group on Effective Exchange of Information. Over 168 TIEAs have
been signed by various States, most within recent months. The IBFD Tax Treaties Unit has obtained,
electronically formatted, and incorporated all of these agreements in our database which already
includes over 6,000 tax related treaties. These agreements, which the IBFD has completely
catalogued, will form the newly established network of information sharing.
These research activities will become part of our holdings at the IBFD Tax Library and will be
available for students and academics to use as tools in future tax research. Additionally, the IBFD
commercially offers these resources to the tax community which includes our extensive tax treaty
database.
Bulletin for International Taxation___________________________
Moving Towards Better Transparency and Exchange of Information on Tax Matters
Jeffrey Owens- Director of the Centre for Tax Policy Administration, OECD.
Date: 28 October 2009
In this short contribution, Jeffrey Owens, Director of the OECD's Centre for Tax Policy
Administration, gives his thoughts on developments on transparency and the exchange of
information regarding tax matters. In this respect, he emphasizes the role of the OECD's Global
Forum and the recent conclusion of exchange of information and other agreements by a number of
jurisdictions that are intended to promote transparency and cooperation in the tax field.
Over the past ten months, there has been a revolution in the tax world. More than a decade of work
led by the OECD, together with the political leadership of the G20, has permitted unprecedented
progress towards better transparency and exchange of information.
For too long it has been possible for a taxpayer to hide income and assets from the tax authorities by
taking advantage of bank secrecy or other impediments to information exchange. This will no longer
be the case. Cooperation between tax administrations is now becoming the rule. The threshold of
tolerance for tax evasion has dropped to zero. And in the context of the current crisis, governments
need tax revenue and citizens need to be reassured that the tax burden is being fairly shared.
Over the last year, all 87 jurisdictions covered by the OECD's Global Forum assessment have
endorsed and committed to implement the standards. Many jurisdictions are also concluding
agreements to exchange information which meet this standard.
The OECD has been leading this work for more than a decade. It created the Global Forum to ensure
that both OECD Member countries and interested non-OECD countries could have input into the
process. This approach has proved right, as is demonstrated by the growing number of jurisdictions
involved in the OECD's work. Eighty-seven jurisdictions were assessed by the Global Forum in 2009,
as reflected in the annual assessment released on 31 August 2009. [1] The new standards on
transparency and exchange of information are now clearly defined and universally accepted.
At the time of the G20 summit in London on 2 April 2009, the OECD's Secretary-General issued a
Progress Report based on the Global Forum's ongoing assessment. This set an initial threshold of 12
agreements that meet the standard to distinguish between those jurisdictions which have
substantially implemented the standards and those which have not. The Report is updated regularly
to reflect the progress made. [2]
An increasing number of jurisdictions are already considered to have substantially implemented the
OECD's standards, although there are some issues about the quality and economic relevance of
some of these agreements.
Since its creation in 2000, the Global Forum has offered an open, international platform to promote
the exchange of information. It has created standards that are now internationally agreed. It has also
collected data on the implementation of such standards in more than 80 jurisdictions and published
this information in annual reports since 2006.
It is this decade of technical work, which has provided the basis for the unprecedented progress
towards more transparency that can be seen over the last ten months, i.e.:
– all 87 countries surveyed by the Global Forum have now endorsed the standards and agreed
to implement them;
– all OECD Member countries now accept the standards as reflected in the OECD and UN
Model Tax Conventions and are active in terms of implementation;
– there are no countries remaining on the OECD list of uncooperative jurisdictions;
– significant financial centres, such as Hong Kong and Singapore, have proposed legislation to
implement the internationally agreed tax standards and have begun the process of updating
their treaty network. Macau passed such legislation in August 2009;
– in Latin America, considerable progress involving Chile, Costa Rica, Guatemala and Uruguay
can been seen, with all of these countries taking actions that will enable them to implement
the standards; and
– over 100 tax information exchange agreements (TIEAs) have now been signed and many
more are under negotiation, with Caribbean, European and Pacific island countries.
More information on this progress can be found in the 2009 Assessment Report, which was issued to
coincide with the Global Forum held in Mexico on 1 and 2 September 2009.
The universal acceptance of the standards must now be followed by their effective implementation
and operation.
This was the main focus of the fifth Global Forum meeting in Mexico in September 2009. At this
meeting, 178 participants from over 70 jurisdictions and international organizations:
– established a robust peer review mechanism;
– expanded the number of participating countries, including developing countries;
– put in place new governance structures and new work methods; and
– explored mechanisms to speed up the negotiations of agreements.
Obtaining agreements on these conclusions [3] reveals that the participating jurisdictions have a
clear commitment to advance in this area.
To conclude, there are many important and significant tasks that lie ahead of the Global Forum, but
the author is confident that the challenges can be met. This has been done in the past. In this
respect, the work of the Sub-Group on Level Playing Field Issues, the Joint Ad-Hoc Group on
Accounts and the Working Group on Exchange of Information have all established a legacy of
confidence and cooperation on which the reformulated Forum can rely.
1. Available at www.oecd.org/document/23/0,3343,en_2649_33745_43555607_1_1_1_1,00.html.
2. The results are available at www.oecd.org/dataoecd/50/0/43606256.pdf.
3. Details are available at www.oecd.org/ctp.
The views expressed in this article are those of the author and do not necessarily reflect those of the OECD or its
Member countries. The author can be contacted at [email protected].
© Copyright 2009 IBFD All rights reserved
International Bureau of Fiscal Documentation
Appendix I: Tax Information Disclosure Legislation
Appendix I contains examples of recently enacted legislation to regulate the disclosure of taxpayer
information for both individuals and corporations. The measures range from creation of new
disclosure events to the identity and responsibilities of disclosing parties. The IBFD will closely
monitor the effects of this legislation to determine its effectiveness from tax evasion and tax
fraud.
Australia
The Assistant Treasurer has proposed in the Tax Laws Amendment Bill 2009 (Confidentiality of
Taxpayer Information)and explanatory materials to implement the single and consolidated
framework outlined in the Treasury discussion paper released in 2006, to govern the protection and
disclosure of taxpayer information received by the Australian Taxation Office in the course of
administering the taxation laws.
The proposed legislation will standardize taxation secrecy and disclosure provisions across 18
taxation Acts to address inconsistencies and ambiguities with the current provisions.
In addition to standardizing existing taxation secrecy and disclosure provisions, the new framework
also makes it clear that the future disclosure of taxpayer information should only be permitted
where the public benefit from the disclosure outweighs taxpayer privacy.
Other key features of the new framework include that:
– it maintains current levels of disclosures that can be made by the ATO to other government
agencies;
– it introduces some new disclosure provisions, where the public benefit outweighs taxpayer
privacy;
– it includes clear rules to govern the on-disclosure of taxpayer information provided by the
ATO to another agency or entity;
– it clarifies that there is no prohibition on the disclosure of taxpayer information that is
lawfully available to the public; and
– it provides that a taxpayer's consent can not in and of itself authorize the disclosure of their
information.
European Union
On 25 June 2009, the Commission announced that it has sent a reasoned opinion (the second stage
of the infringement procedure of Art. 226 of the EC Treaty) to Belgium, Greece, Ireland,
Luxembourg, Poland and Portugal for failure to implement the latest Accounting Directive (Directive
2006/46/EEC), which increases the maximum thresholds that Member States may apply in
determining which companies may be exempted from certain disclosure requirements. In addition,
the Directive extends the disclosure requirements for companies on material transactions with
related parties, such as key management members and spouses of board members, and on
arrangements that do not appear in the balance sheet, such as transactions or agreements which
companies may have with entities. Finally, the Directive obliges to disclose an annual corporate
governance statement as a specific and clearly identifiable section of the annual report.
After the implementation of the Directive non-listed European companies will also have to provide
more information to the investors and other citizens about risks they are facing. The burden for
small and medium-sized companies will, however, be reduced by exempting them from certain
reporting requirements.
The Directive had to be implemented by 5 September 2008. If Belgium, Ireland, Greece,
Luxembourg, Poland and Portugal do not implement the Directive in the next two months, the
Commission may decide to refer the matter to the ECJ.
France
The Ministry of Finance issued an order (arrêté ministériel) on 7 October 2009 (published in the
Journal Officiel of the same date) compelling with immediate effect French banks to disclose, in an
appended document to the annual financial results, a list of their establishments operating in
jurisdictions reputed to be tax havens (i.e. territories without a tax information exchange agreement
with France). The disclosure shall include "a description of the nature of the activities operated by
those undertakings" and also "the company name, the percentage of assets, the voting rights and
the juridical form". This obligation covers branches, subsidiaries, and all kinds of "controlling
shareholdings".
Italy
On 24 September 2009, the Italian Tax Authorities issued Ministerial Circular No. 42/E (the Circular)
aimed at clarifying the new information to be reported in a specific section (the Archivio) of the
Central Tax Register (Anagrafe Tributaria).
The Anagrafe Tributaria is a system aimed at collecting and processing tax information, and it is
based on various electronic archives compiled by different information centres. It gathers and
classifies data included in tax returns as well as data derived from any subsequent audits.
Pursuant to Art.7 Para. 6 of Presidential Decree No. 605 dated 29 September 1973, Italian financial
institutions act as information centres. Accordingly, banks, credit institutes, post offices and other
financial intermediaries are required to disclose to the Archivio all the information related to
taxpayer's bank transactions.
Specific instructions on such disclosure procedure are included in the Ministerial Circular No. 18//E
dated 4 April 2007.
Pursuant to Art. 7 Para. 7 of Presidential Decree No. 605 dated 29 September 1973, foreign branches
and/or foreign offices of Italian financial institutions are subject to the same reporting obligations as
Italian operators.
As clarified by the Circular, the information included in the Archivio and reported by the foreign
branches/offices of Italian financial institutions may became relevant in respect to investigations,
aimed at disclosing assets held abroad by Italian taxpayers and not properly disclosed by the
taxpayers, in violation of the specific provision contained in the Law Decree no. 167 dated 28 June
1990 as converted into Law No. 227 dated 4 August 1990 (known as Monitoraggio Fiscale).
Netherlands
The State Secretary of Finance in a press release of 6 April 2009, indicated that individuals, who do
not declare their income pursuant to the tax amnesty programme, would have to pay a penalty of at
least 300% of the additional tax due or tax evaded upon discovery of unreported foreign bank
accounts.
The Ministry of Finance issued a second press release on 6 April 2009 to clarify that, at this stage, it
is only a proposal, i.e. the Secretary wants to increase the penalty from 100% to 300%.
OECD
The heads and deputy heads of revenue bodies from over 34 economies met in Paris, France on
2829 May 2009 for the fifth meeting of the OECD's Forum on Tax Administration (FTA). As a result of
the discussions, and building on the outcomes from the FTA meeting in Cape Town of 2008, the FTA
agreed to continue:
– Improving the tax administration, taxpayer services and tax compliance – both nationally
and internationally: In this regard, the revenue bodies were determined to improve taxpayer
services and will undertake further work to share information and expertise to enable
revenue bodies to prevent, detect and respond to noncompliance, including in relation to
offshore arrangements.
– Promoting strong corporate governance in the area of tax: The FTA administrations will
continue to engage with business and with the agencies responsible for the development of
corporate governance codes and guidelines with a view to ensuring tax compliance.
– Supporting tax administrations in developing economies: The revenue bodies will increase
their understanding of the needs of developing countries in the area of tax administration
and share relevant products, experience and expertise.
Also, two reports were issued at this meeting:
– the first is related to Building Transparent Compliance by Banks; while
– the second report deals with Engaging with High Net Worth Individuals (HNWI) on Tax
Compliance.
In the report on building transparent compliance by banks, the FTA acknowledges that it can be
difficult for revenue bodies to understand the complex financial products and transactions used by
banks, and to distinguish those which carry a tax risk due to the complex structured finance
transactions. In this regard, the revenue bodies recognized the need to develop the necessary skills
to better understand complex financial products and differentiate those that should be regarded as
aggressive from a tax perspective. The report states that revenue bodies should develop response
strategies that improve transparency and compliance.
In the report related to HNWI, the FTA also recognized that the HNWI segment is of particular
interest for tax administrations because of the:
– complexity of their affairs and the large numbers of entities they may control;
– amounts of tax revenue at stake;
– opportunity to undertake aggressive tax planning; and
– impact on overall integrity of tax system.
This report acknowledges that in order to improve compliance, tax administrations could consider:
– changing the structure of their operations to effectively focus resources and rely on
international cooperation, at both a strategic and operational level, and
– sharing information and expertise between tax administrations, particularly on cross-border
dealings.
It was also suggested that tax administrations should also strive to provide maximum guidance on
voluntary disclosure rules and programmes, whilst dealing firmly with those who commit tax evasion
and fail to come forward before intervention by the authorities.
Portugal
Significant anti-tax fraud and evasion measures have recently been enacted for the disclosure of
transfers of funds to tax havens
Law 94/2009, published on the 1 September 2009, and already in force, establishes that credit and
financial institutions must report to the Portuguese Tax Authorities (PTA) any transfer of funds of
more than EUR 12,500 to entities located in tax havens (as defined), unless the transfer is already
reportable under a different legislation. This measure applies to transfers made in 2009, which
should be reported before the end of July 2010.
The respective standard form was published on 18 September 2009. Reportable information
includes:
– the identification of the bank accounts;
– the tax number of the account-holder (taxpayer);
– the amount of the deposits, the balance of the accounts at 31 December;
– the reason for the transfer; and
– the country of destination.
The standard form must be filed electronically before the end of July of the following year.
Bank secrecy further curtailed
Law 94/2009 also establishes that the PTA is now allowed to override bank secrecy provsions
without the agreement of the account-holder (taxpayer) in these additional cases:
– the taxpayer did not file a tax return which was legally obliged;
– the PTA needs to analyse documents supporting the accounting records of taxpayers subject
to personal or corporate income tax;
– the taxpayer benefits from a privileged tax regime, and it is necessary to control the
required application criteria; and
– the requirements to perform a tax assessment based on indirect methods are met.
The PTA's decision has to be duly supported, and must be notified to the taxpayer within 30 days.
Personal income tax special rate – unjustified wealth increases
Further, Law 94/2009:
– establishes a special rate of 60%, which now applies to unjustified wealth increases of more
than EUR 100,000; the burden of proof is shifted to the taxpayer, who has to justify the
wealth increase; and
– requires taxpayers subject to personal income tax to declare in their income tax return the
existence and identification of bank accounts or securities portfolios deposited with non-
resident financial institutions.
Granting of credit disallowed to non-cooperating tax havens or to unknown ultimate beneficial
owners
Ruling 7/2009, of the Bank of Portugal (BoP), published in the Official Gazette of the 1 September
2009, and in force as from 2 September 2009, forbids the granting of credit to entities located in a
non-cooperating tax havens or when the ultimate beneficial owner is unknown.
The Ruling defines as "tax haven" a jurisdiction that characterizes itself for attracting a significant
volume of activity with non-residents, due to:
– less demanding regimes for the authorization of banking and supervisory activities;
– special regime of bank secrecy;
– existence of tax advantages;
– different legislation for residents and non-residents; or
– facilitation in the creation of special purpose vehicles.
The Ruling also defines as "non-cooperating tax haven" one where the respective domestic law has
limitations on the provision of information to the BoP, for the purposes of prudential supervision
(particularly the identification of the ultimate beneficial owner of the entities to which credit is
granted).
This Ruling applies to credit institutions and financial dealers resident for tax purposes in Portugal, as
well as to Portuguese branches of non-resident credit institutions.
The entities to which the Ruling applies should provide to the BoP a statement issued by the
competent prudential supervisory authorities of the tax havens in which it is intended to carry out
credit operations, to ensure that those jurisdictions will not prevent the provision of the information
mentioned above; otherwise, that jurisdiction will be categorized as a "non-cooperating
jurisdiction".
South Africa
New reportable arrangements legislation enters into force
Reportable arrangements legislation came into force in 2005 and provided for the reporting of two
classes of arrangements:
– those that resulted in a tax benefit and were subject to an agreement that provided for the
variation of interest, fees, etc. if their actual tax benefits differed from the anticipated tax
benefits; and
– those related to certain hybrid debt and equity instruments.
New reportable arrangements legislation, which is contained in Sec. 80M to 80T of the Income Tax
Act 1962, entered into force on 1 April 2008.
Reportable arrangements
The new reportable arrangements legislation is generally triggered where an arrangement gives rise
to a tax benefit and:
– provides for interest, fees, etc. that are partly or wholly dependent on the assumptions
relating to the tax treatment of that arrangement (other than a change in law);
– has any of the characteristics of, or characteristics which are substantially similar to, the
indicators of a lack of commercial substance in terms of the general anti-avoidance rule;
– is or will be disclosed by any participant as a financial liability for the purposes of General
Accepted Accounting Practice (although not for income tax purposes);
– does not result in a reasonable expectation of a pre-tax profit for any participant; or
– results in a reasonable expectation of a pre-tax profit for any participant that is less than the
value of those tax benefits to that participant on a present-value basis.
Specific reporting of hybrid equity and debt instruments is retained, but the 5-year redemption
threshold has been extended to 10 years.
The Minister of Finance's authority to include or exclude arrangements for disclosure by way of
regulation has also been retained.
Excluded arrangements
The new reportable arrangements legislation provides an exclusion for any arrangement where the
tax benefit from the arrangement:
– does not exceed ZAR 1 million; or
– is not the main, or one of the main, purpose of the arrangement.
The exclusions for arrangements that are unlikely to be tax-driven (e.g. the most basic versions of
loans, leases, share transactions and collective investment scheme investments) have been retained.
Responsibility for reporting
The responsibility for disclosing a reportable arrangement is principally placed on its promoter.
In the absence of a resident promoter, the responsibility falls on all participants unless that
participant has written confirmation that the required disclosure has been made by another
participant.
Disclosure must be made within 60 days of funds flowing, or liabilities being incurred, in terms of the
arrangement.
Penalty for non-disclosure
A penalty of ZAR 1 million is imposed for non-disclosure, which may be reduced where:
– there are extenuating circumstances and the non-disclosure is remedied within a reasonable
time; or
– the penalty is disproportionate in relation to the tax benefit from the arrangement.
United States
Legislation was introduced on 27 October 2009 into the tax- writing committees of the US House of
Representatives (the House Ways and Means Committee) and the US Senate (the Senate Finance
Committee) to prevent tax avoidance by means of offshore financial accounts. The legislation is
entitled the Foreign Account Tax Compliance Act of 2009 and was introduced as H.R. 3933 and S.
1934. According to the press release, the bill would require foreign financial institutions, foreign
trusts, and foreign corporations to provide information about their US account holders, grantors,
and owners. According to estimates, the bill would prevent US individuals from evading USD 8.5
billion in US taxes over the next 10 years.
The bill proposes increasing the disclosure requirements for foreign accounts as well as
implementing new underpayment penalties and extending the related statutes of limitations. The
bill would increase disclosure requirements in acquiring or forming a foreign entity and also increase
the reporting requirements for passive foreign investment companies (PFICs) and financial
institutions. The bill further addresses the proper beneficiaries with respect to foreign trusts and
creates new reporting requirements and penalties for foreign trusts. Further, the bill also will
provide that dividend equivalent payments received by foreign persons on notional principal
contracts would be treated as dividends subject to US withholding tax. The proposal to codify the
economic substance doctrine, which was included in an earlier version of a similar bill, is reportedly
not included in the current legislation.
The US Joint Committee on Taxation, a nonpartisan committee of the United States Congress, has
released a technical explanation of the Act. As well, the White House released a statement from the
President commending the proposed legislation.
Additionally, the US Treasury Department released a statement from US Treasury Secretary Timothy
Geithner applauding the bill stating that the "legislation fits well into the (US) Administration's dual-
track strategy of improving our domestic tax laws while increasing global cooperation on tax
information exchange to help narrow the tax gap and create the fairer tax system we need."
If approved by the tax-writing committees, the legislation will be reported to the full House of
Representatives and full Senate for consideration.
International Bureau of Fiscal Documentation
Appendix II: Voluntary Disclosure
Appendix II contains summaries of the various methods of voluntary disclosure and other tax
amnesty enacted by major powers over the recent years. Some countries such as Latvia and
Germany have permanently enacted legislation to encourage the disclosure of unreported or
underreported assets. The summaries below have all been enacted, due in a large part, to the
opening of transparency and information sharing with offshore jurisdictions.
Italy
Scope
Effective 15 September 2009, qualified Italian taxpayers that are fiscally resident in Italy are allowed
to regularize funds and qualified assets that are held abroad as of 31 December 2008 and that have
not been declared to the Italian Tax Authorities (ITA).
The benefit of the Italian voluntary disclosure program (the Amnesty) are granted only if the eligible
taxpayer has failed to comply with the reporting obligation and has not received formal notice of a
tax or criminal procedure at the time of the filing of the confidential return
Eligible Persons
The amnesty is open to Italian resident:
• Individuals;
• Non-commercial entities; and
• Non-commercial partnerships or similar entities (the Resident Eligible Person)2.
Italian resident individuals that are engaged in a trade or business and Italian resident professionals
are eligible to enter, but commercial entities (that is, corporations or commercial partnerships) can’t
directly benefit from it3. A Resident Eligible Person can enter the Amnesty only if he has failed to
comply with one or more of the foreign asset reporting requirements4. A Resident Eligible Person
that holds foreign assets through a pass-through entity that is a conduit (i.e. that is, a revocable trust
in which the settlor has, de facto, the power to dispose of, and benefit from, the assets formally held
by the trust) may benefit from the Amnesty.
The Amnesty can also be entered into by the heirs of a decedent person if the decedent was an
Italian resident at the time that the foreign asset reporting requirements were violated.
2 For purposes of the amnesty, nonresident individuals that have transferred their residency to a low-tax jurisdiction may opt to be
deemed Italian residents.
3 Some controlled foreign corporations can access the amnesty, but the benefits of the amnesty are transferred to the corporations’
Italian resident shareholders.
4 A taxpayer who has made a filing omission or an incomplete filing but has complied with foreign asset reporting obligations
cannot use the amnesty.
Assets Covered
The assets covered by the amnesty are foreign assets held as of 31 December 2008, and they vary
according to whether they are being repatriated in Italy or regularized and left offshore.
Foreign assets that can be repatriated, regardless of whether the issuer is an Italian resident, include
cash, stocks, and similar financial instruments listed, no listed, or over the counter; bonds;
investment fund units; and insurance policies. Also loans granted by an Italian Eligible Person to a
non-resident can be repatriated.
Foreign assets that can be regularized include all assets that can be repatriated and offshore real
estate properties, boats, and jewellery, provided the assets have the potential to produce foreign-
source income taxable in Italy.
No asset can be regularized if it is located in a country or jurisdiction that does not exchange
information with the Italian tax authorities5. For purposes of the amnesty, the country where the
foreign asset is held is the country where the asset was on 5 August 2009.
If the foreign assets held as of 31 December 2008, have been sold or disposed of before the
amnesty, the taxpayer can repatriate (or regularize) the consideration received for the foreign assets
or the assets purchased with such consideration.
Procedure
To complete the repatriation of qualified undisclosed foreign assets, the Resident Eligible Person
must file a confidential statement with an Italian financial intermediary and pay the 5 percent tax
(the Extraordinary Tax).
The statement must include a description of the value of the undisclosed foreign assets held as of 31
December 2008, and the mandate to the financial intermediary to receive the foreign assets in a
dedicated secret account and to pay the Extraordinary Tax due.
The taxpayer must also transfer the foreign assets to the secret account. There is no official guidance
on how to calculate the value of the assets reported in the confidential statement.
The repatriation may also be completed by carrying the foreign assets across the Italian border. In
such a case the taxpayer must report that transfer to the Italian customs authority.
The repatriation is complete, and the Resident Eligible Person can benefit from the Amnesty, on the
date when the intermediary acquires the formal custody of the foreign assets and pays the
5 Before the latest amendments, for a foreign asset to be eligible for regularization it had to be located either in an EU member state
or in a European Economic Area member state, provided that state exchanges information with the Italian tax administration. Real
estate property located in a non-EU member state or in an EEA member state that does not exchange information could not be part
of the amnesty, as that property cannot be physically repatriated or regularized. However, under recently approved amendments all
the foreign assets held offshore can be regularized provided that the foreign country exchanges information with the Italian tax
administration. Under the legislation in force a real estate property located in the U.S. (provided all the other conditions for the
amnesty are met) can be regularized.
extraordinary tax due, regardless of whether the transfer of assets within the Italian territory occurs
later.
The assets deposited with the intermediary are held in secret accounts and the details are not
reported to the Italian tax authority.
The income produced by the repatriated assets between 1 January 2009, and the filing of the
confidential statement is, in principle, subject to tax and must be reported on the taxpayer’s annual
tax return.
The regularization procedure is similar to the repatriation procedure. Besides filing the confidential
statement, the taxpayer must comply with other requirements, depending on the type of foreign
assets to be regularized.
The financial intermediary, as the withholding agent, must include in its annual return the total of
the repatriated or regularized assets held in its accounts. Data on the owners of the assets are not
included in the annual return. The financial intermediary must report to the tax authorities the
regularized assets, along with information on the beneficiary of those assets. No report need be filed
for repatriated assets.
The repatriation triggers no automatic reporting obligation for the financial intermediary, whereas
the regularization triggers it for the intermediary to report to the Italian tax authority the details of
the transaction. The assets that have been repatriated are deposited with the intermediary in special
accounts. The intermediary does not report the details of those accounts to the Italian tax
authorities.
Malta
Malta’s Minister of Finance in Malta, Hon. Dr. Tonio Fenech, has announced in September 2009 that
there would be an amnesty for tax payers who had fallen behind in their tax payments. Amongst the
main reasons for the introduction of such a measure was an attempt by the Government to recover
amounts due also in light of a forecasted drop in taxes due including income taxes in the coming
year.
Requirements
The amnesty shall therefore apply to tax payers who had arrears in their income tax payments. Tax
payers with arrears in payments dating back to 1998, would benefit from a 90 percent reduction on
the interest and fines which would usually be due. On the other hand, tax payers with arrears dating
to before 1997, and therefore before the systems at the Inland Revenue Department were not
computerised, would be entitled to pay 75 percent of the balance due.
Defaulters would be informed of the scheme in a letter which would list the amounts they owed and
what they would be paying if they took up the said Amnesty. Applicants have until 15th
January 2010
to apply for the scheme. The scheme is voluntary but applicants would be required to drop any
objections or claims they might have.
Turkey
On 22 November 2008, Law No. 5811 on "The inclusion of assets into the national economy"
introduced a preferential tax regime for foreign income and capital and assets which might be
qualified as a tax amnesty. The main purpose of the law was to encourage legitimization of domestic
and foreign capital and income.
The most important features of the amnesty are summarized below:
Eligible assets
The following assets of individuals and companies were eligible for the amnesty:
– foreign assets such as cash, foreign currency, gold, securities and other capital market
instruments transferred to Turkey;
– immovable property owned abroad, which was declared and recorded in Turkey; and
– non-registered domestic movable and immovable assets, which were upon legitimization
invested and recorded as capital.
Foreign assets and immovable property
Foreign assets of individuals and companies acquired before 1 October 2008 and held abroad had to
be declared at their market value. The declaration had to be done by 28 February 2009 before
banks, intermediary institutions or tax offices. The assets had to be transferred to Turkey and
deposited with a bank or intermediary institution within a month after the declaration date. In the
case of immovable property, its value was only declared, registered in the books and taxed at the
relevant rate.
A one-off tax at 2% was levied on the market value of the assets transferred, provided that they
were duly documented and recorded. This tax was not deductible from any taxable income and
could not be credited against any other tax.
Domestic assets
Individual income taxpayers and corporate income taxpayers had to declare their domestic non-
registered movable and immovable assets at their market value to tax offices by 28 February 2009.
The movable assets had to be deposited with a bank or an intermediary institution. The assets had
to be recorded in the books and capitalized within 6 months after the declaration date.
A one-off tax at 5% was levied on the market value of the assets legitimized. This tax was not
deductible from any taxable income and could not be credited against any other tax.
For both the foreign assets transferred and the domestic assets legitimized, no tax examinations will
be held and no additional tax charges be accrued for tax periods before 1 January 2008. It should be
mentioned that although the proposed draft law set the amnesty covering all kinds of criminal
investigations, there had been strong opposition in the public, and also in the parliament, that the
amnesty would unacceptably legitimize money laundering crimes.
Amnesty for foreign income
In addition, the following foreign-source income derived by resident individuals and companies were
exempt from personal income tax and corporate income tax, provided that the income was
transferred to Turkey by 31 May 2009:
– capital gains derived from the disposal of shares and participations in foreign companies;
– foreign-source dividends; and
– business income from foreign permanent establishments of Turkish companies and
individuals.
Liquidation gains derived from abroad by resident individuals and companies were also exempt, if
transferred to Turkey by 31 October 2009.
According to the Explanatory Memorandum to the Law, referring to the worldwide financial crisis
felt already in 2008, the desired effects pursued by the amnesty were (1) to attract financial sources
for investments necessary to alleviate the productivity, employment and inflation problems in
Turkey; (2) to maintain the dynamic economy due to the continuous growth of the Turkish economy
for the past years, (3) to secure an important financial source for tackling the effects of the global
financial crisis with minimum damages, and (4) to strengthen the capital structures of enterprises.
In Turkish tax history, between 1923 and 2004, 37 tax amnesties have been introduced in the form
of a full or partial waiver of taxes, interest or penalties. The average indicates that tax amnesties
have been introduced every two years by the Governments as a measure for higher tax revenues.
Such a frequency, however, puts forth the success of the tax amnesties under criticism. In Turkish
tax literature, such tax amnesties have always been criticized in terms of equality principle, and the
ability to pay principle thereof, set under the Turkish Constitution. Furthermore, historically,
attention must be paid on the somewhat paradox practice of introducing tax amnesties every two
years coupled with frequent additional one-off taxes introduced to tackle budgetary deficits.
The Ministry of Finance announced the total amount of declared funds during the negotiations
conducted in the Parliamentary Budgetary Commission on the proposal for extension of the
amnesty. Accordingly, the total declared funds amounted to TRL 14.8.billion, 72% (TRL 10.7 billion)
of which was foreign assets, while the domestic ones were TRL 4.1. billion. The accrued taxes
amounted to TL 419.1 million (TRL 215 million for foreign and TRL 204 million for domestic assets),
TRL 206.6 million of which have been collected. The Ministry of Finance has expressed that the level
of legitimization of foreign assets was considerably below the expectations, compared to that level
for domestic assets.
United Kingdom
HMRC have published details of their New Disclosure Opportunity (NDO). The NDO applies to
individuals with unpaid taxes in connection with offshore accounts and assets. A disclosure
opportunity window will be opened between 1 September 2009 and 12 March 2010.
Individuals who take advantage of the NDO will face a tax penalty of 10% of the unpaid tax. Those
who do not do so will face a penalty of at least 30%, plus the risk of criminal prosecution, if
subsequently discovered by HMRC.
HMRC have declared that there will be no more of such disclosure opportunities once the NDO
comes to an end.
Special provisions apply for certain individuals who did not take advantage of the Offshore
Disclosure Facility (ODF) (the precursor to the NDO, which was in place during 2007), despite having
been invited to do so by HMRC. Should such inividuals now wish to take advantage of the NDO, the
tax penalty is 20%.
United States
A. Voluntary Disclosure Program
The US Internal Revenue Service (IRS) has published the texts of three internal memoranda
addressed to the Commissioner and Industry Directors of the Large and Mid-size Business Division
(LMSD), the Commissioner and Examination Area Directors of the Small Business / Self Employed
Division (SBSE), and the Criminal Investigation (CI) Directors of Field Operations. The memoranda
and accompanying press release set out a new policy to encourage voluntary disclosure of offshore
bank accounts. Through the memoranda, the IRS has revoked the Last Chance Compliance Initiative
(LCCI) and commenced a new penalty procedure in lieu of other applicable penalties.
All three memoranda are dated 23 March 2009 and have the following subject lines: (i) Emphasis on
and Proper Development of Offshore Examination Cases, Managerial Review, and Revocation of Last
Chance Compliance Initiative; (ii) Authorization to Apply Penalty Framework to Voluntary Disclosure
Requests Regarding Unreported Offshore Accounts and Entities; and (iii) Routing of Voluntary
Disclosure Cases.
The new penalty framework will be in effect from 23 March 2009 to 23 September 2009 and apply
only to voluntary disclosure requests. The new penalty provisions for offshore issues of taxpayers
seeking voluntary disclosures will be:
– The IRS will assess all taxes and interest due for the past 6 years and require filing or
amending all returns, including any relevant information returns and TD Form 90.22-1, the
Report of Foreign Bank and Financial Accounts (FBAR).
– Assessment of either an accuracy-related penalty or a delinquency penalty on all of the past
6 years.
– In lieu of other applicable penalties that may apply, a 20% penalty on the amount in the
foreign bank account in the year with the highest aggregate account or asset value.
– The reduction of the 20% penalty to 5% if the taxpayer did not open the account, there was
no account activity while the taxpayer controlled the account, and all taxes have been paid
on the funds in the account.
As noted above, effective 23 March 2009, the IRS will discontinue the Last Chance Compliance
Initiative (LCCI). Taxpayers who have currently open LCCI examinations may still resolve their cases
under the LCCI if they respond to the IRS examiner within 15 days from the date of their prior
notification.
The memoranda also amend the processing of voluntary disclosure applications and stress the
prioritization of examinations involving offshore transactions and need for managerial oversight. The
new process is that all applications for voluntary disclosure requests will still be examined first by the
CI unit but then centrally processed by the Philadelphia Offshore Identification Unit (POIU). The
memorandum in this case directs agents to Internal Revenue Manual Section 9.5.11.9 for questions
pertaining to taxpayer eligibility for the programme.
B. Extension
The US Internal Revenue Service (IRS) has announced a one-time extension of the deadline for the
special voluntary disclosure. The new deadline is 15 October 2009. Taxpayers originally had until 23
September 2009 to apply for the program. The announcement states there will be no further
extensions.
International Bureau of Fiscal Documentation
Appendix III: Bringing tax transparency in line with OECD standards
Since 2008, the number of information exchange agreements has exponentially increased as
jurisdictions around the world reshape their treaty policy to conform with OECD standards on
information exchange. Over 200 such agreements have been signed in only the past two years.
The role of the IBFD in this regard is the documentation and organization of these agreements.
The IBFD Tax Treaties Unit is composed of several researchers who are in the process of obtaining,
formatting, and cataloguing these agreements in order to make them available to both the
academic community as well as our subscribers. The following appendix is coordinated with the
format of the OECD progress reports and is intended to demonstrate the volume of activity that
has occurred over the past two years. The IBFD has obtained the texts of all of these agreements
which are available on the IBFD’s Tax Treaty Database.
Andorra
- Exchange of Information
Agreement between Andorra
and Argentina
- Exchange of Information
Agreement between Andorra
and Austria
- Exchange of Information
Agreement between Andorra
and Belgium
- Exchange of Information
Agreement between Andorra
and France
- Exchange of Information
Agreement between Andorra
and Liechtenstein
- Exchange of Information
Agreement between Andorra
and Monaco
- Exchange of Information
Agreement between Andorra
and Netherlands
- Exchange of Information
Agreement between Andorra
and San Marino
Anguilla
- Exchange of Information
Agreement between Anguilla
and Denmark
- Exchange of Information
Agreement between Anguilla
and Ireland
- Exchange of Information
Agreement between Anguilla
and Netherlands
- Exchange of Information
Agreement between Anguilla
and United Kingdom
Antigua and Barbuda
- Exchange of Information
Agreement between Antigua
and Barbuda and Australia
- Exchange of Information
Agreement between Antigua
and Barbuda and Denmark
- Exchange of Information
Agreement between Antigua
and Barbuda and Netherlands
- Exchange of Information
Agreement between Antigua
and Barbuda and United
States
Argentina
- Exchange of Information
Agreement between Argentina
and Andorra
- Exchange of Information
Agreement between Argentina
and Monaco
Aruba
- Exchange of Information
Agreement between Aruba
and Bermuda
- Exchange of Information
Agreement between Aruba
and British Virgin Islands
- Exchange of Information
Agreement between Aruba
and Denmark
- Exchange of Information
Agreement between Aruba
and Faroe Islands
- Exchange of Information
Agreement between Aruba
and Finland
- Exchange of Information
Agreement between Aruba
and Greenland
- Exchange of Information
Agreement between Aruba
and Iceland
- Exchange of Information
Agreement between Aruba
and Netherlands Antilles
- Exchange of Information
Agreement between Aruba
and Norway
- Exchange of Information
Agreement between Aruba
and Spain
- Exchange of Information
Agreement between Aruba
and St. Kitts and Nevis
- Exchange of Information
Agreement between Aruba
and St. Vincent and the
Grenadines
- Exchange of Information
Agreement between Aruba
and Sweden
- Exchange of Information
Agreement between Aruba
and United States
Australia
- Exchange of Information
Agreement between Australia
and Antigua and Barbuda
- Exchange of Information
Agreement between Australia
and Bermuda
- Exchange of Information
Agreement between Australia
and British Virgin Islands
- Exchange of Information
Agreement between Australia
and Cook Islands
- Exchange of Information
Agreement between Australia
and Gibraltar
- Exchange of Information
Agreement between Australia
and Guernsey
- Exchange of Information
Agreement between Australia
and Isle of Man
- Exchange of Information
Agreement between Australia
and Jersey
- Exchange of Information
Agreement between Australia
and Netherlands Antilles
Austria
- Exchange of Information
Agreement between Austria
and Andorra
- Exchange of Information
Agreement between Austria
and Gibraltar
- Exchange of Information
Agreement between Austria
and Monaco
- Exchange of Information
Agreement between Austria
and St. Vincent and the
Grenadines
Bahamas
- Exchange of Information
Agreement between Bahamas
and Monaco
- Exchange of Information
Agreement between Bahamas
and San Marino
- Exchange of Information
Agreement between Bahamas
and United Kingdom
- Exchange of Information
Agreement between Bahamas
and United States
Belgium
- Exchange of Information
Agreement between Belgium
and Andorra
Bermuda
- Exchange of Information
Agreement between Bermuda
and Aruba
- Exchange of Information
Agreement between Bermuda
and Australia
- Exchange of Information
Agreement between Bermuda
and Denmark
- Exchange of Information
Agreement between Bermuda
and Faroe Islands
- Exchange of Information
Agreement between Bermuda
and Finland
- Exchange of Information
Agreement between Bermuda
and Germany
- Exchange of Information
Agreement between Bermuda
and France
- Exchange of Information
Agreement between Bermuda
and Netherlands
- Exchange of Information
Agreement between Bermuda
and Greenland
- Exchange of Information
Agreement between Bermuda
and Iceland
- Exchange of Information
Agreement between Bermuda
and Ireland
- Exchange of Information
Agreement between Bermuda
and Mexico
- Exchange of Information
Agreement between Bermuda
and Netherlands
- Exchange of Information
Agreement between Bermuda
and Antilles
- Exchange of Information
Agreement between Bermuda
and New Zealand
- Exchange of Information
Agreement between Bermuda
and Norway
- Exchange of Information
Agreement between Bermuda
and Sweden
- Exchange of Information
Agreement between Bermuda
and United Kingdom
British Virgin Islands
- Exchange of Information
Agreement between British
Virgin Islands and Aruba
- Exchange of Information
Agreement between British
Virgin Islands and Australia
- Exchange of Information
Agreement between British
Virgin Islands and Denmark
- Exchange of Information
Agreement between British
Virgin Islands and Faroe
Islands
- Exchange of Information
Agreement between British
Virgin Islands and Finland
- Exchange of Information
Agreement between British
Virgin Islands and France
- Exchange of Information
Agreement between British
Virgin Islands and Greenland
- Exchange of Information
Agreement between British
Virgin Islands and Netherlands
Antilles
- Exchange of Information
Agreement between British
Virgin Islands and New
Zealand
- Exchange of Information
Agreement between British
Virgin Islands and Norway
- Exchange of Information
Agreement between British
Virgin Islands and Iceland
- Exchange of Information
Agreement between British
Virgin Islands and Netherland
- Exchange of Information
Agreement between British
Virgin Islands and Sweden
- Exchange of Information
Agreement between British
Virgin Islands and United
Kingdom
- Exchange of Information
Agreement between British
Virgin Islands and United
States
Canada
- Exchange of Information
Agreement between Canada
and Netherlands Antilles
Cayman Islands
- Exchange of Information
Agreement between Cayman
Islands and Denmark
- Exchange of Information
Agreement between Cayman
Islands and Faroe Islands
- Exchange of Information
Agreement between Cayman
Islands and Finland
- Exchange of Information
Agreement between Cayman
Islands and France
- Exchange of Information
Agreement between Cayman
Islands and Greenland
- Exchange of Information
Agreement between Cayman
Islands and Iceland
- Exchange of Information
Agreement between Cayman
Islands and Ireland
- Exchange of Information
Agreement between Cayman
Islands and Netherlands
- Exchange of Information
Agreement between Cayman
Islands and New Zealand
- Exchange of Information
Agreement between Cayman
Islands and Norway
- Exchange of Information
Agreement between Cayman
Islands and Sweden
- Exchange of Information
Agreement between Cayman
Islands and United States
Cook Islands
- Exchange of Information
Agreement between Cook
Islands and Australia
- Exchange of Information
Agreement between Cook
Islands and New Zealand
Denmark
- Exchange of Information
Agreement between Denmark
and Anguilla
- Exchange of Information
Agreement between Denmark
and Antigua and Barbuda
- Exchange of Information
Agreement between Denmark
and Aruba
- Exchange of Information
Agreement between Denmark
and Bermuda
- Exchange of Information
Agreement between Denmark
and British Virgin Islands
- Exchange of Information
Agreement between Denmark
and Gibraltar
- Exchange of Information
Agreement between Denmark
and Guernsey
- Exchange of Information
Agreement between Denmark
and Isle of Man
- Exchange of Information
Agreement between Denmark
and Jersey
- Exchange of Information
Agreement between Denmark
and Netherlands Antilles
- Exchange of Information
Agreement between Denmark
and St. Kitts and Nevis
- Exchange of Information
Agreement between Denmark
and St. Vincent and the
Grenadines
- Exchange of Information
Agreement between Denmark
and Turks and Caicos
- Exchange of Information
Agreement between Denmark
and Cayman Islands
Faroe Islands
- Exchange of Information
Agreement between Faroe
Islands and Aruba
- Exchange of Information
Agreement between Faroe
Islands and Bermuda
- Exchange of Information
Agreement between Faroe
Islands and British Virgin
Islands
- Exchange of Information
Agreement between Faroe
Islands and Gibraltar
- Exchange of Information
Agreement between Faroe
Islands and Isle of Man
- Exchange of Information
Agreement between Faroe
Islands and Netherlands
Antilles
- Exchange of Information
Agreement between Faroe
Islands and San Marino
- Exchange of Information
Agreement between Faroe
Islands and Cayman Islands
Finland
- Exchange of Information
Agreement between Finland
and Aruba
- Exchange of Information
Agreement between Finland
and Bermuda
- Exchange of Information
Agreement between Finland
and British Virgin Islands
- Exchange of Information
Agreement between Finland
and Gibraltar
- Exchange of Information
Agreement between Finland
and Guernsey
- Exchange of Information
Agreement between Finland
and Isle of Man
- Exchange of Information
Agreement between Finland
and Jersey
- Exchange of Information
Agreement between Finland
and Netherlands Antilles
- Exchange of Information
Agreement between Finland
and Cayman Islands
France
- Exchange of Information
Agreement between France
and Andorra
- Exchange of Information
Agreement between France
and Bermuda
- Exchange of Information
Agreement between France
and British Virgin Islands
- Exchange of Information
Agreement between France
and Cayman Islands
- Exchange of Information
Agreement between France
and Gibraltar
- Exchange of Information
Agreement between France
and Guernsey
- Exchange of Information
Agreement between France
and Isle of Man
- Exchange of Information
Agreement between France
and Jersey
- Exchange of Information
Agreement between France
and Liechtenstein
- Exchange of Information
Agreement between France
and San Marino
- Exchange of Information
Agreement between France
and Turks and Caicos
Germany
- Exchange of Information
Agreement between Germany
and Bermuda
- Exchange of Information
Agreement between Germany
and Gibraltar
- Exchange of Information
Agreement between Germany
and Guernsey
- Exchange of Information
Agreement between Germany
and Isle of Man
- Exchange of Information
Agreement between Germany
and Jersey
- Exchange of Information
Agreement between Germany
and Liechtenstein
Gibraltar
- Exchange of Information
Agreement between Gibraltar
and Australia
- Exchange of Information
Agreement between Gibraltar
and Austria
- Exchange of Information
Agreement between Gibraltar
and Denmark
- Exchange of Information
Agreement between Gibraltar
and Faroe Islands
- Exchange of Information
Agreement between Gibraltar
and Finland
- Exchange of Information
Agreement between Gibraltar
and France
- Exchange of Information
Agreement between Gibraltar
and Germany
- Exchange of Information
Agreement between Gibraltar
and Greenland
- Exchange of Information
Agreement between Gibraltar
and Ireland
- Exchange of Information
Agreement between Gibraltar
and New Zealand
- Exchange of Information
Agreement between Gibraltar
and Portugal
- Exchange of Information
Agreement between Gibraltar
and United Kingdom
- Exchange of Information
Agreement between Gibraltar
and United States
Greenland
- Exchange of Information
Agreement between
Greenland and Aruba
- Exchange of Information
Agreement between
Greenland and Bermuda
- Exchange of Information
Agreement between
Greenland and British Virgin
Islands
- Exchange of Information
Agreement between
Greenland and Cayman Islands
- Exchange of Information
Agreement between
Greenland and Gibraltar
- Exchange of Information
Agreement between
Greenland and Guernsey
- Exchange of Information
Agreement between
Greenland and Isle of Man
- Exchange of Information
Agreement between
Greenland and Jersey
- Exchange of Information
Agreement between
Greenland and Netherlands
Antilles
- Exchange of Information
Agreement between
Greenland and San Marino
Guernsey
- Exchange of Information
Agreement between Guernsey
and Australia
- Exchange of Information
Agreement between Guernsey
and Denmark
- Exchange of Information
Agreement between Guernsey
and Finland
- Exchange of Information
Agreement between Guernsey
and France
- Exchange of Information
Agreement between Guernsey
and Germany
- Exchange of Information
Agreement between Guernsey
and Greenland
- Exchange of Information
Agreement between Guernsey
and Iceland
- Exchange of Information
Agreement between Guernsey
and Ireland
- Exchange of Information
Agreement between Guernsey
and New Zealand
- Exchange of Information
Agreement between Guernsey
and Norway
- Exchange of Information
Agreement between Guernsey
and Sweden
- Exchange of Information
Agreement between Guernsey
and the Faroe Islands
- Exchange of Information
Agreement between Guernsey
and the Netherlands
- Exchange of Information
Agreement between Guernsey
and United Kingdom
- Exchange of Information
Agreement between Guernsey
and United States
Iceland
- Exchange of Information
Agreement between Iceland
and Aruba
- Exchange of Information
Agreement between Iceland
and Bermuda
- Exchange of Information
Agreement between Iceland
and British Virgin Islands
- Exchange of Information
Agreement between Iceland
and Cayman Islands
- Exchange of Information
Agreement between Iceland
and Guernsey
- Exchange of Information
Agreement between Iceland
and Isle of Man
- Exchange of Information
Agreement between Iceland
and Jersey
- Exchange of Information
Agreement between Iceland
and Netherlands Antilles
Ireland
- Exchange of Information
Agreement between Ireland
and Anguilla
- Exchange of Information
Agreement between Ireland
and Bermuda
- Exchange of Information
Agreement between Ireland
and Cayman Islands
- Exchange of Information
Agreement between Ireland
and Gibraltar
- Exchange of Information
Agreement between Ireland
and Guernsey
- Exchange of Information
Agreement between Ireland
and Isle of Man
- Exchange of Information
Agreement between Ireland
and Jersey
- Exchange of Information
Agreement between Ireland
and Liechtenstein
- Exchange of Information
Agreement between Ireland
and Turks and Caicos
Isle of Man
- Exchange of Information
Agreement between Isle of
Man and Australia
- Exchange of Information
Agreement between Isle of
Man and Denmark
- Exchange of Information
Agreement between Isle of
Man and Faroe Islands
- Exchange of Information
Agreement between Isle of
Man and Finland
- Exchange of Information
Agreement between Isle of
Man and France
- Exchange of Information
Agreement between Isle of
Man and Germany
- Exchange of Information
Agreement between Isle of
Man and Greenland
- Exchange of Information
Agreement between Isle of
Man and Iceland
- Exchange of Information
Agreement between Isle of
Man and Ireland
- Exchange of Information
Agreement between Isle of
Man and New Zealand
- Exchange of Information
Agreement between Isle of
Man and Norway
- Exchange of Information
Agreement between Isle of
Man and Sweden
- Exchange of Information
Agreement between Isle of
Man and the Netherlands
- Exchange of Information
Agreement between Isle of
Man and United Kingdom
- Exchange of Information
Agreement between Isle of
Man and United States
Jersey
- Exchange of Information
Agreement between Jersey
and Australia
- Exchange of Information
Agreement between Jersey
and Denmark
- Exchange of Information
Agreement between Jersey
and Finland
- Exchange of Information
Agreement between Jersey
and France
- Exchange of Information
Agreement between Jersey
and Germany
- Exchange of Information
Agreement between Jersey
and Greenland
- Exchange of Information
Agreement between Jersey
and Iceland
- Exchange of Information
Agreement between Jersey
and Ireland
- Exchange of Information
Agreement between Jersey
and New Zealand
- Exchange of Information
Agreement between Jersey
and Norway
- Exchange of Information
Agreement between Jersey
and Sweden
- Exchange of Information
Agreement between Jersey
and the Faroe Islands
- Exchange of Information
Agreement between Jersey
and the Netherlands
- Exchange of Information
Agreement between Jersey
and United Kingdom
- Exchange of Information
Agreement between Jersey
and United States
Liechtenstein
- Exchange of Information
Agreement between
Liechtenstein and Andorra
- Exchange of Information
Agreement between
Liechtenstein and France
- Exchange of Information
Agreement between
Liechtenstein and Germany
- Exchange of Information
Agreement between
Liechtenstein and Ireland
- Exchange of Information
Agreement between
Liechtenstein and Monaco
- Exchange of Information
Agreement between
Liechtenstein and St. Vincent
and the Grenadines
- Exchange of Information
Agreement between
Liechtenstein and United
Kingdom
- Exchange of Information
Agreement between
Liechtenstein and United
States
Mexico
- Exchange of Information
Agreement between Mexico
and Bermuda
- Exchange of Information
Agreement between Mexico
and Netherlands Antilles
Monaco
- Exchange of Information
Agreement between Monaco
and Andorra
- Exchange of Information
Agreement between Monaco
and Argentina
- Exchange of Information
Agreement between Monaco
and Austria
- Exchange of Information
Agreement between Monaco
and Bahamas
- Exchange of Information
Agreement between Monaco
and Belgium
- Exchange of Information
Agreement between Monaco
and Liechtenstein
- Exchange of Information
Agreement between Monaco
and Samoa
- Exchange of Information
Agreement between Monaco
and San Marino
- Exchange of Information
Agreement between Monaco
and United States
Netherlands
- Exchange of Information
Agreement between
Netherlands and Andorra
- Exchange of Information
Agreement between
Netherlands and Anguilla
- Exchange of Information
Agreement between
Netherlands and Antigua and
Barbuda
- Exchange of Information
Agreement between
Netherlands and Bermuda
- Exchange of Information
Agreement between
Netherlands and British Virgin
Islands
- Exchange of Information
Agreement between
Netherlands and Cayman
Islands
- Exchange of Information
Agreement between
Netherlands and Guernsey Isle
of Man
- Exchange of Information
Agreement between
Netherlands and Jersey
- Exchange of Information
Agreement between
Netherlands and Samoa
- Exchange of Information
Agreement between
Netherlands and St Kitts and
Nevis
- Exchange of Information
Agreement between
Netherlands and St. Vincent
and the Grenadines
- Exchange of Information
Agreement between
Netherlands and Turks and
Caicos
Netherlands Antilles
- Exchange of Information
Agreement between
Netherlands Antilles and
Aruba
- Exchange of Information
Agreement between
Netherlands Antilles and
Australia
- Exchange of Information
Agreement between
Netherlands Antilles and
British Virgin Islands
- Exchange of Information
Agreement between
Netherlands Antilles and
Bermuda
- Exchange of Information
Agreement between
Netherlands Antilles and
Canada
- Exchange of Information
Agreement between
Netherlands Antilles and
Denmark
- Exchange of Information
Agreement between
Netherlands Antilles and Faroe
Islands
- Exchange of Information
Agreement between
Netherlands Antilles and
Finland
- Exchange of Information
Agreement between
Netherlands Antilles and
Greenland
- Exchange of Information
Agreement between
Netherlands Antilles and
Iceland
- Exchange of Information
Agreement between
Netherlands Antilles and
Mexico
- Exchange of Information
Agreement between
Netherlands Antilles and New
Zealand
- Exchange of Information
Agreement between
Netherlands Antilles and
Norway
- Exchange of Information
Agreement between
Netherlands Antilles and Spain
- Exchange of Information
Agreement between
Netherlands Antilles and St.
Kitts and Nevis
- Exchange of Information
Agreement between
Netherlands Antilles and
Sweden
- Exchange of Information
Agreement between
Netherlands Antilles and
United States
New Zealand
- Exchange of Information
Agreement between New
Zealand and Bermuda
- Exchange of Information
Agreement between New
Zealand and British Virgin
Islands
- Exchange of Information
Agreement between New
Zealand and Cayman Islands
- Exchange of Information
Agreement between New
Zealand and Cook Islands
- Exchange of Information
Agreement between New
Zealand and Gibraltar
- Exchange of Information
Agreement between New
Zealand and Guernsey
- Exchange of Information
Agreement between New
Zealand and Isle of Man
- Exchange of Information
Agreement between New
Zealand and Jersey
- Exchange of Information
Agreement between New
Zealand and Netherlands
Antilles
Norway
- Exchange of Information
Agreement between Norway
and Aruba
- Exchange of Information
Agreement between Norway
and Bermuda
- Exchange of Information
Agreement between Norway
and British Virgin Islands
- Exchange of Information
Agreement between Norway
and Guernsey
- Exchange of Information
Agreement between Norway
and Isle of Man
- Exchange of Information
Agreement between Norway
and Jersey
- Exchange of Information
Agreement between Norway
and Netherlands Antilles
- Exchange of Information
Agreement between Norway
and Cayman Island
Portugal
- Exchange of Information
Agreement between Portugal
and Gibraltar
Samoa
- Exchange of Information
Agreement between Samoa
and Monaco
- Exchange of Information
Agreement between Samoa
and Netherlands
- Exchange of Information
Agreement between Samoa
and San Marino
San Marino
- Exchange of Information
Agreement between San
Marino and Andorra
- Exchange of Information
Agreement between San
Marino and Bahamas
- Exchange of Information
Agreement between San
Marino and Faroe Islands
- Exchange of Information
Agreement between San
Marino and France
- Exchange of Information
Agreement between San
Marino and Greenland
- Exchange of Information
Agreement between San
Marino and Monaco
- Exchange of Information
Agreement between San
Marino and Samoa
Spain
- Exchange of Information
Agreement between Spain and
Aruba
- Exchange of Information
Agreement between Spain and
Netherlands Antilles
St. Kitts and Nevis
- Exchange of Information
Agreement between St. Kitts
and Nevis and Aruba
- Exchange of Information
Agreement between St. Kitts
and Nevis and Denmark
- Exchange of Information
Agreement between St. Kitts
and Nevis and Netherlands
- Exchange of Information
Agreement between St. Kitts
and Nevis and Netherlands
Antilles
St. Vincent and the
Grenadines
- Exchange of Information
Agreement between St.
Vincent and the Grenadines
and Aruba
- Exchange of Information
Agreement between St.
Vincent and the Grenadines
and Austria
- Exchange of Information
Agreement between St.
Vincent and the Grenadines
and Denmark
- Exchange of Information
Agreement between St.
Vincent and the Grenadines
and Liechtenstein
- Exchange of Information
Agreement between St.
Vincent and the Grenadines
and Netherlands
Sweden
- Exchange of Information
Agreement between Sweden
and Aruba
- Exchange of Information
Agreement between Sweden
and Bermuda
- Exchange of Information
Agreement between Sweden
and British Virgin Islands
- Exchange of Information
Agreement between Sweden
and Cayman Islands
- Exchange of Information
Agreement between Sweden
and Guernsey
- Exchange of Information
Agreement between Sweden
and Isle of Man
- Exchange of Information
Agreement between Sweden
and Jersey
- Exchange of Information
Agreement between Sweden
and Netherlands Antilles
The Faroe Islands
- Exchange of Information
Agreement between the Faroe
Islands and Guernsey
- Exchange of Information
Agreement between the Faroe
Islands and Jersey
Turks and Caicos
- Exchange of Information
Agreement between Turks and
Caicos and Denmark
- Exchange of Information
Agreement between Turks and
Caicos and France
- Exchange of Information
Agreement between Turks and
Caicos and Ireland
- Exchange of Information
Agreement between Turks and
Caicos and Netherlands
- Exchange of Information
Agreement between Turks and
Caicos and United Kingdom
United Kingdom
- Exchange of Information
Agreement between United
Kingdom and Anguilla
- Exchange of Information
Agreement between United
Kingdom and Bahamas
- Exchange of Information
Agreement between United
Kingdom and Bermuda
- Exchange of Information
Agreement between United
Kingdom and British Virgin
Islands
- Exchange of Information
Agreement between United
Kingdom and Gibraltar
- Exchange of Information
Agreement between United
Kingdom and Guernsey
- Exchange of Information
Agreement between United
Kingdom and Isle of Man
- Exchange of Information
Agreement between United
Kingdom and Jersey
- Exchange of Information
Agreement between United
Kingdom and Liechtenstein
- Exchange of Information
Agreement between United
Kingdom and Turks and Caicos
United States
- Exchange of Information
Agreement between United
States and Antigua and
Barbuda
- Exchange of Information
Agreement between United
States and Aruba
- Exchange of Information
Agreement between United
States and Bahamas
- Exchange of Information
Agreement between United
States and British Virgin
Islands
- Exchange of Information
Agreement between United
States and Cayman Islands
- Exchange of Information
Agreement between United
States and Gibraltar
- Exchange of Information
Agreement between United
States and Guernsey
- Exchange of Information
Agreement between United
States and Isle of Man
- Exchange of Information
Agreement between United
States and Jersey
- Exchange of Information
Agreement between United
States and Liechtenstein
- Exchange of Information
Agreement between United
States and Monaco
- Exchange of Information
Agreement between United
States and Netherlands
Antilles