There are some five hundred tax information exchange treaties now entered into globally, broadly following the OECD model, but very little case law determining how they operate in practice. The following memorandum describes a recent Cayman Islands Court of Appeal case that confirms that requests for information pursuant to any such treaties entered into with the Cayman Islands must be executed strictly in accordance with their terms, particularly as relating to protections and safeguards afforded to persons who are the subject of information requests.

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