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Information exchange under tax treaty: requests allowed regardless of residency, limited by territorial possession or control. Article 2 provides that information shall be exchanged without regard to whether the person to whom the information relates is, or whether the information is held by, a resident of a Contracting Party, but the Requested Party is not obliged to provide information which is neither held by its authorities nor is in the possession or control of persons who are within its territorial jurisdiction.
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.
Information exchange under tax treaty: requests allowed regardless of residency, limited by territorial possession or control.
Article 2 provides that information shall be exchanged without regard to whether the person to whom the information relates is, or whether the information is held by, a resident of a Contracting Party, but the Requested Party is not obliged to provide information which is neither held by its authorities nor is in the possession or control of persons who are within its territorial jurisdiction.
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