Exchange of information mandates mutual tax information sharing for assessment, collection and enforcement with confidentiality safeguards. Article 26 requires competent authorities to exchange necessary tax information, including documents, for assessment, collection, enforcement, prosecution or appeal determination; such information must be treated as secret and disclosed only to persons or authorities concerned, subject to restrictions where measures would conflict with domestic law, information is unobtainable in the normal course, or disclosure would reveal trade secrets or offend public policy, while requested States must use their information gathering powers even without a domestic interest and bank or fiduciary status is not a per se ground for refusal.
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 mandates mutual tax information sharing for assessment, collection and enforcement with confidentiality safeguards.
Article 26 requires competent authorities to exchange necessary tax information, including documents, for assessment, collection, enforcement, prosecution or appeal determination; such information must be treated as secret and disclosed only to persons or authorities concerned, subject to restrictions where measures would conflict with domestic law, information is unobtainable in the normal course, or disclosure would reveal trade secrets or offend public policy, while requested States must use their information gathering powers even without a domestic interest and bank or fiduciary status is not a per se ground for refusal.
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