The Dutch government is reportedly preparing to sign a "considerable number"
of Tax and Information Exchange Agreements (TIEAs) with offshore and onshore
jurisdictions as it commences a drive to reduce tax evasion.
The Dutch newspaper Financiele Dagblad has reported Robert ten Have, head of
the bilateral tax treaties department of the Dutch Finance Ministry as announcing
that the strategy is designed to allow the Dutch authorities to "see what's
going on in these territorial jurisdictions".
The Dutch Finance Ministry has already announced the thirty countries that
it wishes to conclude tax information exchange agreements with during 2007,
and these include: Algeria, Australia, Azerbeidzjan, Brazil, Canada, China,
Costa Rica, Cuba, Cyprus, France, Germany, Ghana, Hong Kong, Indonesia, Iran,
the Isle of Man, Japan, Kenya, Kyrgyzstan, Libya, Malaysia, Mexico, Peru, Saudi-Arabia,
South Korea, Switzerland, Turkey, Turkmenistan, the United Arab Emirates and
the United Kingdom.
The Netherlands has already been active in the area of bilateral tax agreements
with offshore territories, having concluded TIEAs with the UK offshore dependencies
of Jersey and the Isle of Man. Talks are also underway with Jersey's neighbour,
Guernsey.
The agreement between the Netherlands and the Isle of Man was said to be the
first of its kind between a small international business centre and an OECD
member. This agreement, part of a wider economic treaty, was ratified by the
Isle of Man's parliament, the Tynwald, at its May 2006 sitting, and on 21 July
2006, the Isle of Man Government received confirmation that the Netherlands
had also ratified the agreements.
In addition to the TIEA, the Netherlands/Isle of Man agreements included: a
shipping and aircraft taxation agreement; a ‘transfer pricing’ agreement;
an agreement that Manx subsidiaries of Dutch companies will not experience any
tax issues now that the Isle of Man has introduced its ‘0/10’ company
tax system; and a commitment to work towards a full double taxation agreement
between the Isle of Man and the Netherlands.
Jersey's agreement with the Netherlands, signed in June 2006, allows the exchange
of bank and other information on request relating to both criminal and civil
tax matters. For criminal tax matters, information exchange can apply whether
the investigation relates to conduct before or after the coming into force of
the agreement. For civil tax matters, such an exchange can apply only in respect
of taxable periods beginning on or after the date of entry into force.