Exchange of information: treaty obligation to share tax-related documents between jurisdictions with confidentiality and limited-use safeguards and limits. Article 26 provides for exchange of information necessary for carrying out the Agreement and domestic tax laws, requiring competent authorities to share documents or certified copies for assessment, collection, enforcement, prosecution, or appeals. Information received must be kept secret as under domestic law and disclosed only to persons or authorities concerned with the specified tax purposes, with permitted disclosure in public court proceedings. Paragraph 2 limits the obligation by excluding measures contrary to domestic law or practice, information not obtainable in the normal administration, and information whose disclosure would reveal trade secrets or contravene public policy.
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: treaty obligation to share tax-related documents between jurisdictions with confidentiality and limited-use safeguards and limits.
Article 26 provides for exchange of information necessary for carrying out the Agreement and domestic tax laws, requiring competent authorities to share documents or certified copies for assessment, collection, enforcement, prosecution, or appeals. Information received must be kept secret as under domestic law and disclosed only to persons or authorities concerned with the specified tax purposes, with permitted disclosure in public court proceedings. Paragraph 2 limits the obligation by excluding measures contrary to domestic law or practice, information not obtainable in the normal administration, and information whose disclosure would reveal trade secrets or contravene public policy.
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