Regulatory Regimes and Liability Issues
Anna Masutti and Filippo Tomasello
Edited by Fabiana Di Porto and Rupprecht Podszun
Chapter 5 focuses on administrative assistance in the collection of tax claims. While a specific provision of the OECD Model, Art. 27, introduces rules that contracting states may wish to implement in their treaties, this provision so far has not been as successful as Art. 26 of the same Model. Perhaps the movement of ratification of the Council of Europe/OECD multilateral convention on administrative assistance in tax matters, which entails a provision on assistance in the recovery of tax receipts (Art. 11), will contribute to the development of such type of assistance.
Chapter 12 focuses on the Common Reporting Standard (CRS), which has been published by the OECD on July 2014 and represents the global standard of due diligence for the automatic exchange of information of financial accounts. The various conditions of the CRS implementation, as well as the definition of the essentials actors, such as the reporting financial intermediaries, are described as well as some already emerging issues.