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 ... Summary
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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