The OECD agreement on exchange of information on tax matters : an analysis of its adequateness as a tool to combat tax havens

Abstract

The aim with this thesis is to investigate whether Tax Information Exchange Agreements (TIEA) serve as adequate tools to combat the existence of tax havens and its harmful consequences. More specifically, this thesis pursues to establish what features of tax havens that the OECD Agreement on Exchange of Information on Tax Matters helps putting a stop to, and what characteristics of a tax haven that the respective agreement is unable to stop. The thesis is organized as follows. Chapter one provides the reader with the necessary background information with respect to defining and identifying tax havens. In chapter two, the most common structures within tax havens will be described. The reader will also be provided with examples on how tax havens are used to evade tax. The OECD model TIEA and its commentary will be assessed in chapter three. The TIEA entered into by Norway and Isle of Man will also be studied for illustrating purposes. The incentives among the contracting parties are discussed in the fourth and fifth part of the thesis. Chapter six concludes.