Key Takeaways
- A TIEA enables information exchange on request, so it shares data rather than providing the tax relief a double tax treaty offers.
- Requests follow a defined path from a foreign authority to a Vanuatu response, and only information within the agreed scope can be sought.
- Confidentiality safeguards limit how exchanged information may be disclosed and used by the requesting partner.
- Vanuatu's commitments align with OECD Global Forum transparency standards, shaping what non-resident owners can practically expect going forward.
TIEAs in Vanuatu: What Information Exchange on Request Means for You
A Tax Information Exchange Agreement (TIEA) is a bilateral instrument that lets one country ask another for tax-related information about a named taxpayer. Vanuatu has signed 14 such agreements, and the body responsible for handling them is the Director of Customs and Inland Revenue (DCIR), who acts as the country's Competent Authority for exchange of information. These arrangements matter to anyone who holds a bank account, owns a company, or controls a structure in the jurisdiction while being tax-resident somewhere else.
This article explains how TIEAs in Vanuatu operate, which partner countries can make requests, what information is reachable, how a request is processed, and where the regime is heading under OECD Global Forum review. It is most relevant to non-resident owners, investors, and their advisers whose home country is among the jurisdictions able to request information.
How a TIEA Differs from a Double Tax Treaty: Information, Not Relief
A TIEA and a Double Tax Treaty (DTT) are easy to confuse, yet they do opposite jobs. A DTT allocates taxing rights and grants relief through credits, exemptions, or reduced withholding; a TIEA grants no relief at all and simply creates an obligation to hand over information held domestically.
The TIEA model grew out of the OECD's 1998 report on harmful tax practices, with the first agreements taking effect in 2002. Information moves only on request, never automatically, and only in connection with civil or criminal tax matters.
Vanuatu maintains both kinds of instrument in parallel: one DTT and 14 TIEAs. The Australia-Vanuatu agreement is a clear example, letting the Australian Commissioner of Taxation request information held in the islands to support enforcement of Australian tax law, without altering any tax liability.
A TIEA never reduces what you owe. It only obliges one state to supply tax information to another upon a properly made request.
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Vanuatu's TIEA Network: How Many Agreements and With Which Partners
Fourteen bilateral TIEAs connect the jurisdiction to a defined set of partner countries. Information can be exchanged on request only with those signatories.
| Region | Partner jurisdictions |
|---|---|
| Pacific / Asia | Australia, New Zealand, Korea (Republic of) |
| Nordic | Denmark, Faroe Islands, Finland, Greenland, Iceland, Norway, Sweden |
| Europe | France, Ireland, San Marino |
| Caribbean | Grenada |
The Australia agreement was signed on 21 April 2010 in Devonport and has had effect from 1 January 2011. Ireland's TIEA with the jurisdiction is confirmed on the Irish Revenue portal.
Beyond the bilateral count, the reach is wider than fourteen. Vanuatu, alongside 128 other states, has joined the Convention on Mutual Administrative Assistance in Tax Matters (MAAC), which entered into force for it on 1 December 2018 and extends exchange coverage well past the bilateral list.
No TIEA or tax treaty exists between the islands and the United States, and the US does not appear among the 14 bilateral partners.
The Legal Framework Behind Vanuatu's Commitments to Information Exchange
The operative domestic instrument is the Tax Administration Regulation Order No. 154 of 2019. On 1 January 2020, the role of Competent Authority for exchange of information passed to the DCIR from the Department of Finance and Treasury.
On the same date, a dedicated EOI Unit was set up within DCIR, staffed by three officers. This team manages obligations under both the bilateral TIEAs and the MAAC.
Automatic exchange under the Common Reporting Standard (CRS) sits in Schedule 2 of Part 12 of the same Order, with penalties for non-compliance set out in subsections 52(3) and 52(4). The International Companies Act [Cap 222] is also relevant, since Section 22 deals with information-gathering duties for international companies.
A core principle runs through all of this: a revenue authority's ability to exchange information cannot be blocked by offshore or banking secrecy rules. The earlier International Tax Cooperation Act, under which the Competent Authority was first designated, has been repealed and replaced by the 2019 Order.
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Scope of Information Covered Under a TIEA Request
Requests reach three broad categories of records held in the jurisdiction:
- Bank account information
- Ownership and identity information for legal entities and arrangements
- Accounting records
Each request must clear the "foreseeable relevance" threshold drawn from the OECD Model TIEA. Article 5(1) of the Australia agreement obliges the Competent Authority to provide, on request, information foreseeably relevant to administering or enforcing the requesting state's tax laws.
General sweeps are not allowed. A specific taxpayer must be named, so "fishing expeditions" across classes of account holders fall outside the rules.
The requested state must use all available information-gathering measures even where it has no domestic tax use for the data, and banking secrecy cannot be invoked to refuse a valid request.
How a Request Actually Works: From Foreign Authority to Vanuatu Response
A request begins abroad and lands with the DCIR. The process runs in a recognisable sequence:
- The foreign Competent Authority submits a formal written request to the DCIR, naming the specific taxpayer and explaining why the information is foreseeably relevant.
- The EOI Unit receives the request and gathers the information using its statutory powers.
- The Unit responds, aiming to supply everything requested in a timely manner.
For the Australia agreement, a Memorandum of Understanding addresses cost reimbursement, with anticipated costs between USD 500 and USD 1,000; where costs are likely to exceed that band, Australia would need to agree before the exchange proceeds. Other bilateral arrangements may handle costs differently.
Statutory processing deadlines are not publicly detailed for the jurisdiction. The relevant international benchmarks are the Global Forum's 90-day standard for acknowledging a request and 180-day standard for providing the information.
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Confidentiality, Safeguards and the Limits on Disclosure
Information exchange is not open-ended. The Australia agreement, like all OECD-model TIEAs, builds in safeguards covering confidentiality and legal privilege.
Data received under a TIEA must be kept confidential by the requesting state and may be disclosed only to persons or authorities concerned with assessing, collecting, enforcing, or prosecuting the taxes the agreement covers. Banks in the jurisdiction guarantee client confidentiality and do not release financial or ownership data without proper legal authorisation.
That confidentiality, however, gives way to a valid TIEA or MAAC request. The enacted framework places treaty obligations above domestic secrecy.
Several grounds allow a request to be refused:
- Compliance would disclose a trade secret
- The request runs contrary to public policy (ordre public)
- No specific taxpayer is identified
- The requesting state could not obtain the same information under its own laws
TIEAs and the OECD Global Forum Transparency Standards
The jurisdiction is a member of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes. Its standing there shapes how partner countries and the EU view the regime.
The 2026 supplementary review rates Vanuatu overall Largely Compliant with the exchange-on-request standard. This followed a second-round review whose 2019 report flagged gaps; the country took corrective action and asked for a supplementary review, launched in the fourth quarter of 2024.
Preparation included a mock on-site visit in Port Vila from 23 to 25 April 2024, run with the Asian Development Bank. The 2026 report was approved by the Peer Review and Monitoring Group in March 2026 and published on 29 April 2026.
The review still recommends stronger supervision and enforcement to ensure that ownership, accounting, and banking information is available. The Competent Authority monitors these ratings partly to preserve the country's position with the EU Code of Conduct Group.
What a Non-Resident Owner Should Practically Expect
Two separate channels can move your information abroad. On-request exchange reaches the 14 bilateral partners plus the wider MAAC network; automatic exchange under the CRS runs alongside it.
Under the CRS Multilateral Competent Authority Agreement signed on 21 June 2018, financial institutions report account data to the DCIR, which then exchanges it annually with CRS partner jurisdictions. This operates independently of, and in addition to, on-request TIEA exchanges.
Because the islands levy no corporate or personal income tax, the trigger for a request is almost always a foreign authority investigating a taxpayer under that authority's own laws. If your home country is a TIEA or MAAC partner, treat your bank account data and company ownership records as potentially reachable on a properly made request.
A practical limitation exists. The 2026 report acknowledges that international companies and foundations not registered as taxpayers have not been supervised, so accounting information may not be available for every entity in every case.
If you own an international company, you must keep accounting records and oversee capital and currency flows, even though you are not required to file those records with the DCIR. A Tax Identification Number is mandatory for CRS automatic exchange.
The Outlook: Where Vanuatu's Information Exchange Is Heading
The trajectory points toward fuller compliance. The 2026 "Largely Compliant" rating is an upgrade from the deficiencies recorded in 2019.
Two areas remain flagged: supervision and enforcement around beneficial ownership and accounting records. The DCIR works with the Vanuatu Financial Services Commission, the Financial Intelligence Unit, and the Reserve Bank of Vanuatu to close those gaps and hold a compliant rating, partly to protect standing with the EU Code of Conduct Group.
For CRS, new financial institutions register with the Multi Data Exchange System (MDES) between 1 February and 31 March each year, with reports due by 31 May. As more states join the MAAC, the partner universe will keep growing without any need to negotiate fresh bilateral agreements.
Conclusion
TIEAs do not change your tax bill in Vanuatu, but they do open a clear path for foreign tax authorities to obtain information about you when they have a specific, well-founded reason. With 14 bilateral partners, the MAAC in force, and CRS automatic reporting running in parallel, a non-resident owner should assume that bank and ownership records are reachable by a partner country following the proper process. The regime's "Largely Compliant" rating and continuing reform suggest that reach will broaden rather than narrow. Keeping accurate records and understanding which channels apply to your home country is the practical response.
How Expanship Can Help Your Business in Vanuatu
Expanship supports foreign owners in understanding how TIEAs, the MAAC, and CRS reporting touch their Vanuatu structures, and in keeping ownership and accounting records in the order those frameworks expect. The same team handles the broader requirements of running a foreign-owned entity in the jurisdiction.
- Company formation and structuring
- Registered agent and registered office services
- Tax identification number registration and filing support
- Ongoing compliance and regulatory monitoring
- Accounting and bookkeeping
- Introductions to banking partners
To discuss your situation, contact Expanship Vanuatu.
Frequently Asked Questions
The DCIR records 14 bilateral Tax Information Exchange Agreements. Information can be exchanged on request with those 14 partner jurisdictions, while the Multilateral Convention on Mutual Administrative Assistance in Tax Matters extends coverage further from 1 December 2018.
No bilateral TIEA or tax treaty exists between the two countries, and the US is not among the 14 listed partners. Other US reporting channels operate outside the TIEA framework discussed here.
No. A TIEA only obliges the jurisdiction to supply tax information on request and provides no relief; relief from double taxation comes from a Double Tax Treaty, which is a separate instrument.
No. Domestic confidentiality and banking secrecy cannot be invoked to refuse a valid request, because the enacted framework places treaty obligations above secrecy rules. Banks still protect client data against access that lacks proper legal authorisation.
The 2026 Second Round Supplementary Peer Review rates the jurisdiction overall Largely Compliant with the exchange-on-request standard, an upgrade from the gaps identified in 2019. The Global Forum continues to recommend stronger supervision of ownership, accounting, and banking information.
The request must name a specific taxpayer and explain the foreseeable relevance of the information sought. Broad sweeps across classes of account holders, known as fishing expeditions, are not permitted.
Legal Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal, tax, or professional advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change, and the application of laws can vary widely based on specific facts and circumstances.
Readers should not act upon this information without seeking professional counsel tailored to their individual situation. Expanship and its authors disclaim any liability for actions taken or not taken based on the content of this article.
For specific advice regarding your business setup, compliance requirements, or any legal matters, please consult with qualified legal and tax professionals in the relevant jurisdiction.
