Exchange of information upon request secures cross-border access to financial and ownership records for tax investigations. The competent authority of the Requested Party must provide information on request for treaty tax purposes irrespective of the Requested Party's own tax needs or whether conduct is a domestic crime, using all relevant information gathering measures available. Authorities must be able to obtain records from banks, financial institutions, nominees, trustees and persons acting in fiduciary capacities and secure legal and beneficial ownership information for entities, trusts and foundations, subject to an exception for publicly traded entities where disproportionate difficulties arise. Requests must specify identity, period, nature and form of information, tax purpose, grounds for its presence, possessor details, conformity with domestic law and exhaustion of domestic means, and the Requested Party must acknowledge and promptly act on requests.
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 upon request secures cross-border access to financial and ownership records for tax investigations.
The competent authority of the Requested Party must provide information on request for treaty tax purposes irrespective of the Requested Party's own tax needs or whether conduct is a domestic crime, using all relevant information gathering measures available. Authorities must be able to obtain records from banks, financial institutions, nominees, trustees and persons acting in fiduciary capacities and secure legal and beneficial ownership information for entities, trusts and foundations, subject to an exception for publicly traded entities where disproportionate difficulties arise. Requests must specify identity, period, nature and form of information, tax purpose, grounds for its presence, possessor details, conformity with domestic law and exhaustion of domestic means, and the Requested Party must acknowledge and promptly act on requests.
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