Exchange of information obligations require mutual tax information sharing and active information gathering despite no domestic interest. Competent authorities must exchange information foreseeably relevant for implementing the Agreement or administering and enforcing domestic tax laws, treating received information as secret and limiting disclosure to tax assessment, collection, enforcement, prosecution, appeals and oversight. A State need not act contrary to its laws or administrative practice, supply unobtainable information, or disclose trade or public policy sensitive secrets; however, requested States must use information gathering measures to obtain requested information even without a domestic interest, and cannot refuse solely because information is held by banks, financial institutions, nominees, agents or fiduciaries or concerns ownership interests.
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Provisions expressly mentioned in the judgment/order text.
Exchange of information obligations require mutual tax information sharing and active information gathering despite no domestic interest.
Competent authorities must exchange information foreseeably relevant for implementing the Agreement or administering and enforcing domestic tax laws, treating received information as secret and limiting disclosure to tax assessment, collection, enforcement, prosecution, appeals and oversight. A State need not act contrary to its laws or administrative practice, supply unobtainable information, or disclose trade or public policy sensitive secrets; however, requested States must use information gathering measures to obtain requested information even without a domestic interest, and cannot refuse solely because information is held by banks, financial institutions, nominees, agents or fiduciaries or concerns ownership interests.
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