An Analysis of the “Foreseeable Relevance” Standard and the International Exchange of Tax Information: Are the European Union and the OECD in Agreement?

Abstract

This article examines the standard of “foreseeable relevance” in international exchange of tax information comparatively as set out in the OECD Model and the EU legal framework. It questions whether the new foreseeable relevance standard makes it “manifestly” foreseeable, and whether the European Union and the OECD are in agreement.