Tax examination abroad: cross border interviews and presence allowed with consent and requested State control over procedures. Article 28A permits representatives of a requesting State to enter the requested State to interview individuals and examine records with the prior written ... Summary
Tax examination abroad: cross border interviews and presence allowed with consent and requested State control over procedures.
Article 28A permits representatives of a requesting State to enter the requested State to interview individuals and examine records with the prior written consent of the persons concerned and after notifying the requested State of time and place. It also permits representatives to be present during parts of tax examinations if the requested State agrees, requires the requested State to notify details and procedures, and confirms that all decisions on conducting the examination rest with the requested State.
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