Organisational Aspects
of Exchange of
Authority to Exchange
• Competent Authority
– Ministry of Finance or Tax Administration
– ensures co-operation and consistency
– possible delegation of functions
Exchange of Information
Example of Key Responsibilities - EOI unit
 Processing exchange requests (specific, spontaneous,
automatic, simultaneous audits, public information)
 Collection Assistance
 Negotiating Memorandums of Understanding with treaty
 Processing travel requests to a foreign country
 All requests are sent and reviewed by the Manager
Role of the tax auditor
All exchanges go through the competent authority, but
the tax auditors are usually essential to the process.
They are often responsible for:
– Collecting the information requested by a treaty partner
– Requesting the competent authority obtain information from a
treaty partner in connexion with the management of audit work
– Providing information for spontaneous exchange
– Receiving and acting on information received from a treaty
– Providing and using feedback
Importance of Training
• Informs auditors of their legal obligations
and the opportunities they are offered by
exchange of information
• Promotes exchange of information
• Increases the number of exchanges
• Offer to all parts of the organisation
• Provide information in special bulletins
and reference guides
• Conferences
Training – Subjects covered
Structure and role of the exchange of operations unit
Legal bases for exchange
Information that can be exchanged
Confidentiality rules
Obligations and limitations
Types of exchanges
Important information to provide when making a
• Practical cases
• Reference Guides available
How tax authorities encourage the exchange of
Training, case studies and materials
Field office visits
Other methods
• Discussion of how exchange of
information work can be organized
– How the competent authority unit is set up
– Training and awareness programs
– Integration/relationship between EOI unit
and compliance functions
– Issues encountered
An example - Canada
Minister of National Revenue
Commissioner of the Canada Revenue
Agency (CRA)
Deputy Commissioner of CRA
Compliance Programs Branch
International and Large Business Directorate
Competent Authority Services - Canada
Competent Authority Services
Exchange of Information
Mutual Agreement Procedures
– Technical Cases
Competent Authority
Programs Section
Economic Analysis
Mutual Agreement Procedures –
Advance Pricing Arrangements
Section 1
Mutual Agreement Procedures –
Advance Pricing Arrangements Section
Section 2
Mutual Agreement Procedures –
Advance Pricing Arrangements
Section 3
Mutual Agreement Procedures –
Advance Pricing Arrangements
Section 4

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