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 ... Summary
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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