Tax examination cooperation allows foreign authority presence with consent, subject to domestic procedures and conduct control. Article 6 permits representatives of a requesting Party to enter the requested Party to interview individuals and examine records with the requested Party's domestic law limits and the prior written consent of the individuals concerned, with advance notification of time and place. It also allows such representatives to be present during appropriate parts of a tax examination, subject to the requested Party's procedures and conditions, with notification of the examination's time, place and designated official, while all decisions on the conduct of the examination remain with the Party conducting it.
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 allows foreign authority presence with consent, subject to domestic procedures and conduct control.
Article 6 permits representatives of a requesting Party to enter the requested Party to interview individuals and examine records with the requested Party's domestic law limits and the prior written consent of the individuals concerned, with advance notification of time and place. It also allows such representatives to be present during appropriate parts of a tax examination, subject to the requested Party's procedures and conditions, with notification of the examination's time, place and designated official, while all decisions on the conduct of the examination remain with the Party conducting it.
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