This article analyses the Organisation for Economic Co-operation and Development (OECD) 2002 Model Agreement on Exchange of Information on Tax Matters (hereinafter 'EOI Model' or 'EOI Model Agreement') (hereinafter 'OECD EOI Model' or 'OECD EOI Model Agreement'), providing a critical analysis on whether the provisions being upheld and defended by the OECD EOI Model is too high for developing nations that are still in need of assistance in adapting to the international standards. For that, the article drives from an interpretational paradox surrounding the two most important intergovernmental organizations on international taxation: the United Nations (UN) and the OECD. In doing so, the article strives to convey a legal, technical, and political background to this new fighting round (in political and economic interests) between developed and developing nations, amidst a worldwide, developed-world driven, crisis and recession.
Intertax