International Exchange of Information in the Field of Direct Taxation

Abstract

In connection with continually widening public budget deficits and related attempts of States to remove (or at least to eliminate) unfair tax practices, issues regarding the exchange of information, which is necessary for the proper performance of provisions of conventions for the avoidance of double taxation and/or national laws, have become topical. The purpose of this paper which includes starting points for subsequent analyses is to describe and assess the existing situation in the area of enshrinement of the concept of exchange of information in current conventions for avoidance of double taxation concluded by the Czech Republic according to the state valid on 1 January 2013. Having regard to this objective defined, the authors ignore other aspects such as the existence of memoranda of mutual cooperation concerning the exchange of information, existence of tax information exchange agreements concluded by the Czech Republic and Euroepan Union law in the given area and their contents. They briefly refer to these and other aspects in the chapter called “Discussion” where they point to other research possibilities in this area.