Tax examinations abroad permit access and presence during foreign tax probes, subject to local law, notice and consent.

Permitted procedures allow a requesting State's competent authority to seek entry into the requested State to interview individuals and examine records with prior written consent, subject to reasonable notice and the requested State's laws; the requested State must notify the applicant State of meeting time and place. The requested State may also permit applicant State representatives to be present during parts of a tax examination, and if so must notify the applicant State of the examination time, place, designated official, and required procedures and conditions, while retaining authority over examination conduct.

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