What OECD/COE Convention on Mutual Administrative Assistance in Tax Matters 1988/2010 - AEOI and Tax Information Exchange requires
The Multilateral Convention on Mutual Administrative Assistance in Tax Matters (1988, amended by 2010 Protocol - 147 jurisdictions as of 2025) is the overarching legal basis for the OECD/G20 global tax transparency agenda: it enables automatic exchange of information (AEOI) under the Common Reporting Standard (CRS), spontaneous exchange of BEPS-relevant rulings under BEPS Action 5, simultaneous tax examinations, tax debt collection assistance, and service of foreign tax documents - financial institutions, multinational enterprises, and HNWIs must understand that any income or assets in a participating jurisdiction are reportable to home country tax authorities automatically under CRS, and that tax rulings provided in one jurisdiction are shared with all treaty partners; the Convention is the legal instrument under which over 100 bilateral Competent Authority Agreements (CAAs) for CRS are activated.
Pillar: Tax & Transfer Pricing · Authority: Organisation for Economic Co-operation and Development (OECD) and Council of Europe (COE) - joint secretariat; OECD Global Forum on Transparency and Exchange of Information for Tax Purposes administers peer review · Version: 1.0.0 · Last updated:
Primary source: https://www.oecd.org/tax/exchange-of-tax-information/convention-on-mutual-administrative-assistance-in-tax-matters.htm
SHA-256 integrity: 91f2a5901c35671e2dc5c51865089fc0f910db80488d7918b45b01fb056ceb2d
Primary Citations — 7 traced to source
- {"title":"Multilateral Convention on Mutual Administrative Assistance in Tax Matters (as amended by the 2010 Protocol) - OECD/COE","url":"https://www.oecd.org/ctp/exchange-of-tax-information/convention-on-mutual-administrative-assistance-in-tax-matters.htm","articles":["Article 4 (exchange on request - foreseeably relevant standard)","Article 6 (automatic exchange - basis for CRS MCAA)","Article 7 (spontaneous exchange - BEPS Action 5 rulings)","Article 8 (simultaneous tax examinations)","Article 11 (assistance in collection of tax claims)","Article 17 (service of documents)","Article 21 (limits on obligation to provide assistance - bank secrecy not a ground)","Article 22 (confidentiality - information used for tax purposes only)","Article 28 (entry into force and territorial extension)"]}
- {"title":"OECD Common Reporting Standard (CRS) and Multilateral Competent Authority Agreement (CRS MCAA) - 2014","url":"https://www.oecd.org/tax/automatic-exchange/common-reporting-standard/","articles":["CRS Section I-IX (due diligence procedures)","CRS Annex - Reportable jurisdictions list","CRS MCAA Article 3 (automatic exchange - annual, by 30 September)","CRS MCAA Article 6 (confidentiality and safeguards)","OECD CRS Implementation Handbook 2018 (2nd edition) - due diligence procedures for financial institutions"]}
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