Jefferson P. VanderWolk (Faculty of Law, Chinese University of Hong Kong) has posted The New World of Tax Information Exchange, 13 Asia-Pacific J. Tax'n ___ (2009), on SSRN.  Here is the abstract:

 The smaller financial centers such as Switzerland, Liechtenstein, Hong Kong and other low-tax jurisdictions have no realistic choice but to cooperate with the G-20 and OECD members in agreeing to exchange information related to tax enforcement on the terms that those organizations require. Exchange of information has become like motherhood and apple pie: no one can possibly be against it, in principle. The twelve-year campaign of the OECD Committee on Fiscal Affairs against tax havens has succeeded in this much, at least. Two major events helped make it happen, in addition to the UBS and Liechtenstein affairs described earlier. First, the September 11, 2001 terrorist attacks in the United States galvanized the Bush Administration, which had hitherto been a defender of tax havens, to put real pressure on them to exchange information as part of the battle against the international financing of terrorist activities. Second, the financial crisis of 2008 and 2009 created an unprecedented need for new tax revenue to fund domestic economic stimulus programs in the G-20 countries.

It is likely that this is just an initial stage in a process that will eventually result in broader and more automatic exchanges of information between tax authorities. The “motherhood and apple pie” principle will again come into play if and when the G-20 leaders begin to call for such broader exchanges. Any country that dares to oppose them will risk becoming an international pariah and losing a substantial amount of legitimate international business. It is also possible that large developing countries such as China and India will become strong proponents of expanded exchange of information practices in the future.

The article discusses the dramatic and rapid developments in tax information exchange globally during 2009 and early 2010.