Exchange of information enables tax authorities to request banking, ownership and trust records subject to domestic law. Requested competent authorities must provide information relevant to tax administration regardless of domestic tax interest, using all relevant information gathering measures and, where allowed, depositions and authenticated originals. Authorities must be able to obtain bank, financial, nominee, trustee and comprehensive legal and beneficial ownership information for entities including companies, collective investment vehicles, trusts and foundations, with a proportionality exception for publicly traded entities. Requests must show foreseeable relevance by identifying the subject, period, nature and tax purpose of the request, grounds for possession, known custodians, legal conformity and efforts exhausted; requested authorities must confirm receipt within sixty days and notify inability or obstacles within ninety days.
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 enables tax authorities to request banking, ownership and trust records subject to domestic law.
Requested competent authorities must provide information relevant to tax administration regardless of domestic tax interest, using all relevant information gathering measures and, where allowed, depositions and authenticated originals. Authorities must be able to obtain bank, financial, nominee, trustee and comprehensive legal and beneficial ownership information for entities including companies, collective investment vehicles, trusts and foundations, with a proportionality exception for publicly traded entities. Requests must show foreseeable relevance by identifying the subject, period, nature and tax purpose of the request, grounds for possession, known custodians, legal conformity and efforts exhausted; requested authorities must confirm receipt within sixty days and notify inability or obstacles within ninety days.
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