As outlined in a response to a parliamentary question on 25 February, the Revenue Commissioners have initiated discussions with the Cayman Islands for the negotiation of a tax information exchange agreement, TIEA. First round negotiations have not yet taken place. TIEAs are based on the OECD model agreement on exchange of information in tax matters, which was published in April 2002. The purpose of the model agreement is to promote international co-operation in tax matters through exchange of information. Any TIEA based on the model agreement will require jurisdictions, on request, to exchange bank information as well as information regarding the beneficial ownership of companies, partnerships and trusts. Exchange of information will be required for information relevant to criminal tax matters from 1 January 2004 and from 1 January 2006 for civil tax matters.
In addition to the Cayman Islands, Revenue has initiated discussions with its counterparts in the Isle of Man, Guernsey and Jersey. The Deputy may wish to note that section 38 of the recently enacted Finance Act 2003 contains a provision permitting the Government to enter into tax information exchange agreements.