Exchange of information upon request requires parties to provide relevant tax data and use all available measures to obtain it. Article 5 requires the Requested Party's competent authority to provide information for tax purposes upon request and to use all relevant information-gathering measures if existing holdings are insufficient. Responses may include witness depositions and authenticated originals where permitted by domestic law. Each Party must empower its competent authority to obtain banking and financial records and legal and beneficial ownership information for legal persons, investment vehicles and fiduciary arrangements, subject to proportionality limits for publicly traded entities. Requests must demonstrate foreseeable relevance by supplying specific identifying and evidentiary particulars, and the Requested Party must acknowledge receipt, notify deficiencies promptly, and explain any inability to comply.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Exchange of information upon request requires parties to provide relevant tax data and use all available measures to obtain it.
Article 5 requires the Requested Party's competent authority to provide information for tax purposes upon request and to use all relevant information-gathering measures if existing holdings are insufficient. Responses may include witness depositions and authenticated originals where permitted by domestic law. Each Party must empower its competent authority to obtain banking and financial records and legal and beneficial ownership information for legal persons, investment vehicles and fiduciary arrangements, subject to proportionality limits for publicly traded entities. Requests must demonstrate foreseeable relevance by supplying specific identifying and evidentiary particulars, and the Requested Party must acknowledge receipt, notify deficiencies promptly, and explain any inability to comply.
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