Exchange of information expanded to require broad tax information sharing and assistance in tax collection across jurisdictions.

The Amending Protocol expands cooperative tax administration by broadening Exchange of Information obligations to include foreseeably relevant documents and techniques such as simultaneous examinations, mandates confidentiality and limited use, and requires competent authorities to use normal information gathering measures even absent domestic interest. It creates Assistance in the Collection of Taxes, obliging States to accept and collect or to take conservancy measures for revenue claims of the other State subject to domestic law, public policy and proportionality limits. It also introduces a Limitation of Benefit anti abuse rule, a corresponding adjustment rule for associated enterprises, and targeted clarifications on permanent establishment, interest on transport, dividends and taxable year.

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