Exchange of information obligations require use of information gathering measures with confidentiality and limited disclosure. Contracting States must exchange information foreseeably relevant to implementing the Agreement or administering domestic tax laws; such information is to be treated as secret and disclosed only to persons or authorities concerned with tax assessment, collection, enforcement, prosecution, appeals or oversight and used only for those purposes unless both States' laws permit other uses and the supplying State authorizes them. States need not change laws or produce unobtainable information, but must use information gathering measures to obtain requested information and may not refuse solely because it is held by banks, financial institutions, nominees, fiduciaries or concerns ownership interests.
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 obligations require use of information gathering measures with confidentiality and limited disclosure.
Contracting States must exchange information foreseeably relevant to implementing the Agreement or administering domestic tax laws; such information is to be treated as secret and disclosed only to persons or authorities concerned with tax assessment, collection, enforcement, prosecution, appeals or oversight and used only for those purposes unless both States' laws permit other uses and the supplying State authorizes them. States need not change laws or produce unobtainable information, but must use information gathering measures to obtain requested information and may not refuse solely because it is held by banks, financial institutions, nominees, fiduciaries or concerns ownership interests.
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