Tax treaty definitions clarify key terms, scope of 'relevant' information, and law-applicability for information exchange. Article 4 prescribes key definitions for the Agreement, including territorial scope, Contracting Parties, competent authority, persons, companies, ... Summary
Tax treaty definitions clarify key terms, scope of 'relevant' information, and law-applicability for information exchange.
Article 4 prescribes key definitions for the Agreement, including territorial scope, Contracting Parties, competent authority, persons, companies, publicly traded companies, recognised stock exchanges, collective investment funds, "tax", requesting/requested Party, "information gathering measures" and "information". It requires a broad construction of "relevant" information so that relevance need not be ascertainable until after receipt, and provides that undefined terms default to the domestic law meaning of the applying Party at the relevant time, with tax-law meanings prevailing.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 1 
Join Channel 
