Exchange of information requires Parties to share foreseeably relevant tax information for administration and enforcement purposes. Article 26 obliges competent authorities to exchange foreseeably relevant information for application of the Agreement and for domestic tax administration and enforcement; exchanged information must be kept confidential and used only for specified tax purposes unless authorized otherwise by both Parties. Limitations prohibit requiring measures contrary to a Party's laws or practices, supplying unobtainable information, or disclosing trade secrets or information contrary to public policy. A requested Party must use its information gathering powers to obtain information even without its own tax interest, and cannot refuse solely because information is held by banks, financial institutions, nominees, agents, 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 requires Parties to share foreseeably relevant tax information for administration and enforcement purposes.
Article 26 obliges competent authorities to exchange foreseeably relevant information for application of the Agreement and for domestic tax administration and enforcement; exchanged information must be kept confidential and used only for specified tax purposes unless authorized otherwise by both Parties. Limitations prohibit requiring measures contrary to a Party's laws or practices, supplying unobtainable information, or disclosing trade secrets or information contrary to public policy. A requested Party must use its information gathering powers to obtain information even without its own tax interest, and cannot refuse solely because information is held by banks, financial institutions, nominees, agents, fiduciaries or concerns ownership interests.
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