Tax examinations abroad permit foreign tax officials to interview persons and observe examinations with consent, under requested State control. Article 28A permits representatives of a requesting State to interview individuals and examine records in the requested State with the individuals' prior written consent, and to be present during appropriate parts of tax examinations if the requested State agrees. The requested State must notify the requesting State of the time, place, designated official, and procedural conditions, and retains authority over all decisions concerning the conduct of the examination.
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 permit foreign tax officials to interview persons and observe examinations with consent, under requested State control.
Article 28A permits representatives of a requesting State to interview individuals and examine records in the requested State with the individuals' prior written consent, and to be present during appropriate parts of tax examinations if the requested State agrees. The requested State must notify the requesting State of the time, place, designated official, and procedural conditions, and retains authority over all decisions concerning the conduct of the examination.
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