Tax examinations abroad: consent-based interviews and presence rules enable cross-border assistance while the requested state controls examination conduct. Provision permits entry of requesting-state representatives to interview individuals and examine records with prior written consent and notification to the requested state's competent authority; it also allows presence of requesting representatives during parts of tax examinations in the requested state, subject to notification of time, place, designated official, required procedures and conditions, and confirms that the requested state makes all decisions regarding the conduct of the examination.
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Provisions expressly mentioned in the judgment/order text.
Tax examinations abroad: consent-based interviews and presence rules enable cross-border assistance while the requested state controls examination conduct.
Provision permits entry of requesting-state representatives to interview individuals and examine records with prior written consent and notification to the requested state's competent authority; it also allows presence of requesting representatives during parts of tax examinations in the requested state, subject to notification of time, place, designated official, required procedures and conditions, and confirms that the requested state makes all decisions regarding the conduct of the examination.
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