Exchange of information: mandatory sharing of foreseeably relevant tax data with confidentiality and defined exceptions. Competent authorities must exchange foreseeably relevant tax information, including documents, for administering or enforcing tax laws. Received information is to be kept secret and used only by persons or authorities involved in assessment, collection, enforcement, prosecution, appeals, or oversight, unless both territories' laws and the supplying authority permit other uses. A territory need not act contrary to its laws, supply unobtainable information, or disclose protected trade secrets or information contrary to public policy. Requested territories must use available information gathering measures to obtain requested information even if they have no domestic interest, and cannot refuse solely because the information is held by banks, nominees, agents or fiduciaries or concerns ownership interests.
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: mandatory sharing of foreseeably relevant tax data with confidentiality and defined exceptions.
Competent authorities must exchange foreseeably relevant tax information, including documents, for administering or enforcing tax laws. Received information is to be kept secret and used only by persons or authorities involved in assessment, collection, enforcement, prosecution, appeals, or oversight, unless both territories' laws and the supplying authority permit other uses. A territory need not act contrary to its laws, supply unobtainable information, or disclose protected trade secrets or information contrary to public policy. Requested territories must use available information gathering measures to obtain requested information even if they have no domestic interest, and cannot refuse solely because the information is held by banks, nominees, agents or fiduciaries or concerns ownership interests.
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