The OECD standard model Tax Information Exchange Agreement requires contracting countries to exchange information upon request and, after a great deal of political pressure in the form of an OECD blacklist, many countries scrambled to negotiate and agree these bilateral treaties.

Since then, multilateral TIEAs based on the OECD model are beginning to be seen as a more efficient way forward for the "exchange upon request" model by many countries. At the same time, the OECD Secretariat has produced technical guidance for implementing "automatic exchange" of tax information between countries, a model that the European Union has adopted among its membership in the form of the Savings Tax Directive, and the US Government's Government Accountability Office released a report stating that the U.S. conducts some form of automatic exchange of tax information with 25 countries.

At a time when governments around the world are strapped for cash, are they beginning to see automatic exchange of tax information as a cash cow?