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Exchange of information upon request enables cross border tax inquiries and requires production of bank and ownership records. Exchange of information upon request requires the requested Party's competent authority to provide tax relevant information regardless of whether it needs the information for its own tax purposes and to use all relevant information gathering measures if initial holdings are insufficient. Competent authorities must be able to obtain bank and financial records, fiduciary information and legal and beneficial ownership details across ownership chains for companies, funds, trusts and equivalent entities, subject to a disproportionate difficulties exception for publicly traded companies and public funds. Requests must demonstrate foreseeable relevance through specified identifiers and confirmations; the requested authority must acknowledge receipt, note deficiencies within sixty days, and advise within ninety days if it cannot comply.
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 enables cross border tax inquiries and requires production of bank and ownership records.
Exchange of information upon request requires the requested Party's competent authority to provide tax relevant information regardless of whether it needs the information for its own tax purposes and to use all relevant information gathering measures if initial holdings are insufficient. Competent authorities must be able to obtain bank and financial records, fiduciary information and legal and beneficial ownership details across ownership chains for companies, funds, trusts and equivalent entities, subject to a disproportionate difficulties exception for publicly traded companies and public funds. Requests must demonstrate foreseeable relevance through specified identifiers and confirmations; the requested authority must acknowledge receipt, note deficiencies within sixty days, and advise within ninety days if it cannot comply.
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