Exchange of information: competent authorities may share tax-relevant data subject to confidentiality and use restrictions. Article 26 provides mutual exchange of information between competent authorities for administration of the Convention and domestic tax laws, including documents, without limitation by other Convention articles. Received information must be treated as secret and disclosed only to tax assessment, collection, enforcement, prosecution, appeal or oversight authorities for those purposes; use for other purposes requires bilateral legal permission and supplying-authority authorisation. States are not required to contravene domestic law or supply unobtainable information, nor to disclose protected trade secrets or information contrary to public policy, but must use available information-gathering measures to obtain requested information even when they lack a domestic interest, including information held by financial intermediaries or relating to ownership interests.
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: competent authorities may share tax-relevant data subject to confidentiality and use restrictions.
Article 26 provides mutual exchange of information between competent authorities for administration of the Convention and domestic tax laws, including documents, without limitation by other Convention articles. Received information must be treated as secret and disclosed only to tax assessment, collection, enforcement, prosecution, appeal or oversight authorities for those purposes; use for other purposes requires bilateral legal permission and supplying-authority authorisation. States are not required to contravene domestic law or supply unobtainable information, nor to disclose protected trade secrets or information contrary to public policy, but must use available information-gathering measures to obtain requested information even when they lack a domestic interest, including information held by financial intermediaries or relating to ownership interests.
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