Bermuda has been engaging in tax information exchange with other
jurisdictions since the 1980s. This article, which is based upon a
paper presented at the annual meeting of the International Academy
of Estate and Trusts Law in Tokyo, Japan in May 2019, looks at the
historical trend towards information exchange and the system now in
place under Bermuda law for the production of information pursuant
to tax information exchange agreements (TIEAs).
Carey Olsen Bermuda's Keith Robinson explains in detail why
the current system requires a court order and how the reported case
law dealing with challenges to these TIEA orders provides a useful
insight into the nature and range of the requests being made by
foreign tax authorities.
