The Uruguayan government has announced its commitment to incorporate international standards on transparency and the exchange of tax information into the tax treaties it enters into. This decision was communicated to the Organization for Economic Cooperation and Development (OECD) following a report prepared by that organization that listed Uruguay among the jurisdictions not committed to tax transparency standards. Commitments regarding the exchange of tax information must result from international agreements, with the primary source being that defined by Article 26 of the OECD Model Tax Convention.
This article has been revised on several occasions, with the changes focusing primarily on the requirement that the information be “foreseeably relevant” to the administration and that under no circumstances may banking secrecy be invoked as a reason to refuse the exchange of information. It is in this context that Uruguay has been rapidly signing agreements, and there is pressure from Argentina to sign an agreement on the exchange of information. Dr. Van Raad’s lecture provided a useful contribution to the country’s various legal and economic practitioners involved in this field.
Kess Van Raad is a Professor of Law at Leiden University. He is a member of the Global Law Faculty at New York University School of Law and a Visiting Professor at Peking University School of Law. He chairs the European Association of Tax Law Professors.