Further, the officers of the corporation may be required to establish residence, own real estate, or meet an investment minimum (depending upon the country this may range up to $1 million).
[8] The OECD has established a threshold of bilateral tax-information exchange agreements, twelve, as the minimum which a country is also placed on the “white list” and recognized as having “substantially implemented” internationally agreed tax standards.
The EU requires members to exchange tax information using automatic systems by the end of 2011, which assures that Austria, Belgium and Luxembourg are coming into compliance.
[8] Panama is currently recognized as one of the more attractive countries for legitimate offshore investment as well as for tax evasion, and is on the OECD “grey list”.
Panama does not yet participate in tax-information-exchange treaties; since they tax only domestic income, there is no reciprocal benefit in their sharing information with other governments.
[9] In 2009 the USA initiated increased efforts to close taxation loopholes and identify and prosecute tax evaders using offshore accounts.
As an element of this effort, they have pursued amended tax treaties to offset the banking secrecy laws of nations such as Switzerland.
As with all treaties, this does not come into force until ratified by the appropriate legislative bodies (in this case the U.S. Senate and the Swiss Federal Council and Parliament).