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Key definition
Agreement definition

What does Agreement mean? In competition law practice, an agreement is any form of coordination between undertakings that shows a meeting of minds about market conduct (for example pricing, output, customers or territories). It is not limited to a legally enforceable contract: it includes informal or “gentlemen’s” understandings, oral arrangements, email exchanges and tacit understandings, and extends to decisions of associations of undertakings. Mere parallel conduct is insufficient without evidence of contact or communication. The term is used in legislation and developed by case law: Article 101 TFEU, section 4 of Ireland’s Competition Act 2002, and the UK Chapter I prohibition in the Competition...

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Tax Information Exchange Agreements: OECD model, request-based exchange, 2015 Protocol, and transition to automatic exchange under CRS and the Multilateral Convention

Practice notes
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This PrACTice Note offers a succinct overview of TIEAs.

  • For a broader introduction to tax information exchange across jurisdictions, see Practice Note: Exchange of information on tax matters.
  • For guidance on the OECD's Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Multilateral Convention), see Practice Note: The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM).
  • For an introduction to the automatic exchange of information, including the Foreign Account Tax Compliance Act (known as FATCA) and the Common Reporting Standard (the CRS), see Offshore tax evasion—overview and Practice Note: Automatic exchange of information—outline.

What is a TIEA?

A TIEA is a bilateral arrangement through which jurisdictions agree to co-operate on tax matters by sharing information. Most TIEAs are modelled on the OECD's Model Agreement on Exchange of Information on Tax Matters, published in 2002. Under the Model Agreement, information is exchanged only on request (rather than automatically or spontaneously), and each TIEA sets out the parameters and criteria that the requesting authority must meet when submitting its request...

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Web page updated on 22/05/2026

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