Information exchange under tax treaties applies irrespective of residency but limited by territorial possession or control. Article 2 requires exchange of information without regard to the residency of the person or holder, but a Requested Party is not obliged to provide information that is neither held by its authorities nor in the possession or control of persons within its territorial jurisdiction.
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.
Information exchange under tax treaties applies irrespective of residency but limited by territorial possession or control.
Article 2 requires exchange of information without regard to the residency of the person or holder, but a Requested Party is not obliged to provide information that is neither held by its authorities nor in the possession or control of persons within its territorial jurisdiction.
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