Exchange of Information and Cross-Border Cooperation Between Tax Authorities, IFA congress subject 2013

WebJournal on International Taxation in Sweden, WITS, no 1/2013

 

As you may recall from my webjournal no 8/2012 I volunteered for a place on the discussion panel of the upcoming IFA congress in Copenhagen on the subject ”Exchange of Information and Cross-Border Cooperation Between Tax Authorities”. I was advised by Mr Robert Couzin who is chair of the Permanent Scientific Committee (PSC) of IFA (and an old friend and co-member of both BIAC and ICC back in the nineties) that my request be endorsed by the Swedish branch of IFA.

In doing so, Mr Anders Erasmie, the Swedish branch chairman, reported (curiously coincidentally) that the branch had actually just launched an initiative, under a special ”format”, to nominate suitible Swedish IFA members for participation on the various congress panels. This was an undertaking that would take some time and I would be informed about the outcome of this procedure in due course.

Considering that Swedish participation on congress panels had been very poor in the past I congratulated Mr Erasmie on this initiative. Also, of course,it is a great honour to be nominated for panel participation even if one would not be finally elected by the PSC. From my own experience I can also assure that it is professionally very rewarding and great fun to be on an IFA panel and to meet specialists from other countries on the specific topic.

In late December Mr Erasmie reported that the branch had decided not to support my request and had nominated another Swedish IFA member for the exchange of information topic. Moreover he declared that this nomination should be kept strictly confidential and that it had been revealed to me only because of my prior interest in the matter. Mr Erasmie also reported that there had been no nomination for the other main congress subject (The Taxation of Foreign Passive Income for Groups of Companies) as Sweden would be well represented on that topic by the two Swedish general reporters (Professors Mattias Dahlberg and Bertil Wiman). In line with his his strict policy of secrecy, the reasons for which were declared as ”various”, Mr Erasmie gave no details about any nominations for the panels of the congress seminars.

As you may also recall from my earlier report I raised serious concerns over the general scope of the directives that had been issued by the general reporter and the PSC on the information exchange subject, narrowing the approach to an academic study and interpretation and application of the tax information clauses in exchange of information treaties. Such a discussion before an audience of the worlds 1500 (or so) leading tax experts, in my view, is a waste of time. Like polishing the chandeliers on Titanic! Instead the panel should broaden the discussion to the overall problem of the rampant tax evasion conducted by all the world's tax criminals in this regard threatening the economies of our countries. The recent conviction and prosecution of several high-ranking government officials in Greece are outrageous examples hereof. Beside exchange of information agreements the congress should discuss and strongly support all kinds of legal and administrative measures to counteract the abuse of offshore financial centres and secrecy jurisdictions. In particular IFA should endorse the idea that automatic exchange of information be introduced on a broad scale.

It will be interesting to see to what extent the General Reporter Mr Xavier Oberson, member of the PSC and an expert on Swiss bank secrecy, (see in particular The IFA's Wealth Gram, Volume 1, No 1, Février 2012: Le futur du secret bancaire en Suisse et l'application de la nouvelle politique fiscale en matière d'echange de renseignements fiscaux), and the panel discussion leader (not yet announced) will open up for such a debate.

Stockholm March 2013

Peter Sundgren