In 2014 in the framework of the OECD and according to the Convention on Mutual Administrative Assistance in Tax Matters, the Standard for Automatic Exchange of Financial Account Information was introduced. Its implementation is expected to bring critical changes in the efficiency of international fiscal control. Together with other measures taken by the international community, this protocol may change the nature of taxpayer - tax authority relations as well as bring new interpretations of such institutions as fiscal risks, tax optimization and offshore zone. This article addresses the mutual influence of tax control and tax planning development in course of recent decades, as well as present-day changes and their influence on future behavior of taxpayers involved in international business operations.