Exchange of information: competent authorities must share obtainable tax information to implement the tax treaty and domestic laws. The Protocol requires competent authorities to resolve indeterminate places of effective management by mutual agreement; confirms that treaty provisions ... Summary
Exchange of information: competent authorities must share obtainable tax information to implement the tax treaty and domestic laws.
The Protocol requires competent authorities to resolve indeterminate places of effective management by mutual agreement; confirms that treaty provisions do not bar a State from taxing profits attributable to a permanent establishment under its domestic law; obliges competent authorities to exchange obtainable information for implementing the Agreement or domestic tax laws; and provides that if a State later permits collection assistance with third States it will inform the other State and negotiate incorporation of collection assistance provisions into the Agreement.
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