»Ê¹ÚÌåÓýapp

Requests for information on a speculative basis are not permitted. »Ê¹ÚÌåÓýappre must be foreseeable relevance (IEIM101300) to a particular customer or group of customers. Customers in groups do not have to be individually identified.

Example 1 -the standard is not met

Jurisdiction X asks for details of all properties owned by its residents in Jurisdiction Y. Aside from difficulties in obtaining such information, this is a fishing expedition because there is no specific customer and liability for whom the information is sought. »Ê¹ÚÌåÓýapp request is speculative because it is made in the hope that some useful information can be obtained rather than being linked to a risk with an identifiable customer or group of customers. »Ê¹ÚÌåÓýapp standard of foreseeable relevance is not met.

Example 2 -the standard is met

Jurisdiction X knows that clients of a particular tax agent have taken part in an avoidance scheme which includes investment in a company in Jurisdiction Y. A number of these people are under investigation with significant potential tax liabilities. Tax authorities in Jurisdiction X have not succeeded in obtaining a client list from the tax agent despite exercising all their local information powers. A request is made to Jurisdiction Y to identify all investors in the company with an address in Jurisdiction X. »Ê¹ÚÌåÓýapp standard of foreseeable relevance is met in this request because it can be linked to an identifiable group of customers - investors in the overseas company - and an identifiable tax risk - the avoidance scheme.