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Tax examination cooperation: foreign tax representatives may interview and attend exams subject to consent and host procedures. Article 6 permits representatives of a requesting State to interview individuals and examine records in the requested State with prior written consent and notification of time and place. It also allows such representatives to be present during parts of a tax examination, subject to the requested State's notification of time, place, designated official, and required procedures and conditions, while the requested State retains decision-making authority over 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 examination cooperation: foreign tax representatives may interview and attend exams subject to consent and host procedures.
Article 6 permits representatives of a requesting State to interview individuals and examine records in the requested State with prior written consent and notification of time and place. It also allows such representatives to be present during parts of a tax examination, subject to the requested State's notification of time, place, designated official, and required procedures and conditions, while the requested State retains decision-making authority over the conduct of the examination.
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