Exchange of information: treaty requires information sharing regardless of residency but limited by territorial possession. Article 2 requires Contracting Parties to exchange tax information irrespective of the person's residency or where information is held, but a Requested ... Summary
Exchange of information: treaty requires information sharing regardless of residency but limited by territorial possession.
Article 2 requires Contracting Parties to exchange tax information irrespective of the person's residency or where information is held, but a Requested Party is not obliged to provide information that is neither held by its authorities nor in the possession or control of persons within its territorial jurisdiction.
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