Confidentiality of arbitration proceedings: restricts disclosure to arbitration panel and designated staff under tax-treaty exchange rules. The provision treats arbitration panel members, up to three staff per member, and prospective arbitrators (only as needed to verify qualifications) as persons to whom tax information may be disclosed; information received by them and information received by competent authorities from the panel is regarded as exchanged under the Covered Tax Agreement's exchange-of-information and administrative-assistance provisions. Competent authorities must obtain written confidentiality and nondisclosure undertakings from panel members and staff prior to their participation, consistent with the Covered Tax Agreement and applicable domestic law.
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.
Confidentiality of arbitration proceedings: restricts disclosure to arbitration panel and designated staff under tax-treaty exchange rules.
The provision treats arbitration panel members, up to three staff per member, and prospective arbitrators (only as needed to verify qualifications) as persons to whom tax information may be disclosed; information received by them and information received by competent authorities from the panel is regarded as exchanged under the Covered Tax Agreement's exchange-of-information and administrative-assistance provisions. Competent authorities must obtain written confidentiality and nondisclosure undertakings from panel members and staff prior to their participation, consistent with the Covered Tax Agreement and applicable domestic law.
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