Exchange of information rules require mutual tax information sharing, confidentiality safeguards, and obligations to obtain requested data. The Amending Protocol replaces Article 26 with a comprehensive Exchange of Information regime: competent authorities shall exchange foreseeably relevant tax information, treat received information as secret, restrict disclosure and use to tax assessment, collection, enforcement, appeals or oversight, and permit other uses only if allowed by both States and authorised by the supplying State. Limits preserve domestic law and public policy protections and do not permit refusal solely because the requested information is held by banks, financial institutions, nominees or fiduciaries; contracting States must use their information-gathering measures to obtain requested information.
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 rules require mutual tax information sharing, confidentiality safeguards, and obligations to obtain requested data.
The Amending Protocol replaces Article 26 with a comprehensive Exchange of Information regime: competent authorities shall exchange foreseeably relevant tax information, treat received information as secret, restrict disclosure and use to tax assessment, collection, enforcement, appeals or oversight, and permit other uses only if allowed by both States and authorised by the supplying State. Limits preserve domestic law and public policy protections and do not permit refusal solely because the requested information is held by banks, financial institutions, nominees or fiduciaries; contracting States must use their information-gathering measures to obtain requested information.
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