International Tax Co-Operation via Exchange of Information – The Transatlantic Point of View

There are two main ways of international tax cooperation: unification of tax provisions and exchange of information for tax purposes. Even if the last one is hardly acceptable, still it seems to be more tolerable than the former one. Exchange of information can help combating international tax avoidance and competition. This paper focuses on the exchange of information for interest incomes tax purposes; in particular it focuses on the comparison of the OECD, the EU and the USA positions in this matter. The first part reviews internationally adopted measures on exchange of information, mainly those adopted by the OECD and the European Commission. Here the main principles and advantages of the EU Savings Directive are analysed. In the second part we move to the description of the US rules used in taxation of non-business interest incomes of non-residents. Attention is paid to two issues: position of the USA to exchange of information for tax purposes and US measures to tax interest incomes. Finally, in the third part, we draw several reasons that possibly lie behind the US position