Tax examinations abroad: cross-border interviews and presence during audits allowed subject to consent and domestic law. Article 6 permits representatives of a requesting Party to enter the requested Party to interview individuals and examine records with prior written consent, and to be present during parts of tax examinations. The requested Party must be notified of intended meetings and, where presence is allowed, must inform the requesting Party of the examination's time, place, designated official and required procedures. All decisions on the conduct of the tax examination are made by the Party conducting the examination, and entry or participation is subject to the requested Party's domestic law and procedural conditions.
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.
Tax examinations abroad: cross-border interviews and presence during audits allowed subject to consent and domestic law.
Article 6 permits representatives of a requesting Party to enter the requested Party to interview individuals and examine records with prior written consent, and to be present during parts of tax examinations. The requested Party must be notified of intended meetings and, where presence is allowed, must inform the requesting Party of the examination's time, place, designated official and required procedures. All decisions on the conduct of the tax examination are made by the Party conducting the examination, and entry or participation is subject to the requested Party's domestic law and procedural conditions.
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