Exchange of information: tax authorities must share relevant data subject to confidentiality and limited-use safeguards. Article 25 requires competent authorities to exchange information foreseeably relevant for implementing the Agreement or administering and enforcing domestic tax laws, subject to a confidentiality obligation treating received information as secret and limiting disclosure and use to tax assessment, collection, enforcement, prosecution, appeals and oversight. Exceptions disallow requests that would contravene a State's laws or administrative practice, require unattainable information, or force disclosure of trade secrets or information contrary to public policy, while obliging States to use their information-gathering measures even without a domestic interest and preventing bank or fiduciary status from being a blanket bar to disclosure.
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: tax authorities must share relevant data subject to confidentiality and limited-use safeguards.
Article 25 requires competent authorities to exchange information foreseeably relevant for implementing the Agreement or administering and enforcing domestic tax laws, subject to a confidentiality obligation treating received information as secret and limiting disclosure and use to tax assessment, collection, enforcement, prosecution, appeals and oversight. Exceptions disallow requests that would contravene a State's laws or administrative practice, require unattainable information, or force disclosure of trade secrets or information contrary to public policy, while obliging States to use their information-gathering measures even without a domestic interest and preventing bank or fiduciary status from being a blanket bar to disclosure.
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