The OECD has updated Article 26 of the OECD Model Tax Convention, which sets out the international standard on exchange of information. The standard provides for information exchange on request, where the information is "foreseeably relevant” for the administration of the taxes of the requesting party, regardless of bank secrecy and a domestic tax interest.
The update explicitly allows for group requests. This means that tax authorities are able to ask for information on a group of taxpayers, without naming them individually, as long as the request is not a 'fishing expedition'. This update represents a step forward towards more transparency, according to the OECD’s Centre for Tax Policy.
The new Article 26 facilitates exchange of tax information among law enforcement agencies to fight tax crimes and other criminal activities more effectively. This is in line with the Oslo Dialogue initiative launched by the OECD. All OECD countries have endorsed this latest update.
Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.