In the 2005 version of its model treaty, the OECD introduced a new art. 27 to authorise contracting states to recover taxes on behalf of each other. While membership of the EU carries with it, requirements to uphold administrative and judicial standards and the rule of law, the OECD, in recognising the possibly uneven adherence to such standards of governance, recommends a cautious approach in considering the inclusion of such measures in bilateral treaties.276 The first agreement of this kind in a bilateral treaty is in the 2007 Protocol to the New Zealand treaty, which affords comprehensive assistance as proposed by the OECD Model:

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