Exchange of information limits obligation when information is not held by authorities or within territorial control. A Contracting Party is not required to provide information that is neither held by its authorities nor in the possession or control of persons within its territorial jurisdiction, thereby limiting mutual assistance in tax information exchange to information actually within the State's possession or control.
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 limits obligation when information is not held by authorities or within territorial control.
A Contracting Party is not required to provide information that is neither held by its authorities nor in the possession or control of persons within its territorial jurisdiction, thereby limiting mutual assistance in tax information exchange to information actually within the State's possession or control.
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