AuthorDavid Kerzner, David W. Chodikoff
In recent decades, the topic of cross-border tax information exchange has
attracted considerable academic and policy attention. Beginning w ith the
OECD’s Harmful Tax Competit ion report of 1998, OECD countries (and
later many non-OECD countries) began to emphasize the need for ef‌fective
cross-border exchange mechanisms, mainly to inhibit of‌fshore tax evasion.
The main mechanism derived from these reform ef‌forts is the ta x informa-
tion exchange agreement (TIEA), which is typically negotiated bet ween an
OECD country and countries that are sometimes labelled tax havens. On-
going globalization, technology change, reduced tax revenues, and concerns
about international money laundering and terrorist f‌inancing v ia tax havens
have propelled cross-border tax information exchange to even greater policy
Indeed, there are now over 800 TIEAs worldwide, a stunning develop-
ment in the international tax regime, where change is normally glacially paced.
But do TIEAs work? Will these agreements ef‌fectively inhibit of‌fshore tax eva-
sion and other global f‌inancial crimes? David Kerzner has written the f‌irst
book to critically examine these questions and concludes the answer is no.
According to David, TIEAs do not and will not work effectively for a
number of reasons, including the lack of an automatic exchange mechanism
(as TIEAs emphasize the “information on request” approach). He also wor-
ries that tax havens may not meaningfully cooperate to enforce their TIEAs,
as these countries do not have the political and economic incentives to do
so. He notes that OECD countries further complicate the problem by often
maintaining financial secrecy laws to encourage inward investments from

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