Exchange of information upon request requires broad access to financial and ownership information subject to proportionality and domestic limits. Article 5 requires the competent authority of a requested Party to provide information for treaty tax purposes irrespective of the requested Party's own tax needs, using all relevant information gathering measures where existing holdings are insufficient. Authorities must, to the extent allowed by domestic law, supply depositions and authenticated originals when requested. Parties must ensure access to information from banks, financial institutions, nominees, trustees and on legal and beneficial ownership of entities, trusts and foundations, subject to a proportionality exception for publicly traded entities and public collective investment funds.
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 upon request requires broad access to financial and ownership information subject to proportionality and domestic limits.
Article 5 requires the competent authority of a requested Party to provide information for treaty tax purposes irrespective of the requested Party's own tax needs, using all relevant information gathering measures where existing holdings are insufficient. Authorities must, to the extent allowed by domestic law, supply depositions and authenticated originals when requested. Parties must ensure access to information from banks, financial institutions, nominees, trustees and on legal and beneficial ownership of entities, trusts and foundations, subject to a proportionality exception for publicly traded entities and public collective investment funds.
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