Newsletter-21

392 NEWSLETTER 2016 with regards to tax information exchange, they are classified as states that exercise harmful tax competition 2 . As of July, 2016, 135 countries are States Parties, together with 15 international organizations participating as observers to the Global Forum, including Turkey. In addition to the Global Forum, the Convention on Mutual Ad- ministrative Assistance in Tax Matters (“Convention”) was developed, jointly, by the OECD and the Council of Europe in 1988, and amended by a Protocol in 2010. Although Turkey signed the Convention on 03.11.2011, it has not yet been ratified. Once the Convention is duly ratified and entered into force, it will enable Turkey to exchange tax- related information even with the countries it has not concluded tax information exchange agreement with 3 . Further, the OECD also has a Model Tax Convention on Income and Capital (“Model Convention”) that aims to provide a model for the prevention of double taxation agreements to be concluded between countries 4 . The aims of the Model Convention may be summarized as clarifying and standardizing the fiscal situation of taxpayers who are engaged in activities in other countries, as well as the prevention double taxation. Within this context, Art. 26 of the Model Convention entitled, “ Exchange of Information, ” allows the competent authorities of States Parties to exchange information. Information Exchange within the Scope of Bilateral Agreements The Prevention of Double Taxation Agreements The first appearance of any regulation that aims to facilitate the tax information exchange between countries is through the prevention of double taxation agreements (“PDTAs”). Although in time, the pro- 2 Timur Çakmak , Otomatik Bilgi Değişim Anlaşmalarının Ulusal Vergi Huku- kuna Yansımaları, https://home.kpmg.com/content/dam/kpmg/pdf/2016/06/tr- sorumlu-vergicilik-timur-cakmak.pdf, p. 2. 3 Çakmak , p. 4. 4 For the full text, please see: https://www.oecd.org/ctp/treaties/2014-model-tax- convention-articles.pdf.