Exchange of information: competent authorities must share obtainable tax information to implement the tax treaty and domestic laws. The Protocol requires competent authorities to resolve indeterminate places of effective management by mutual agreement; confirms that treaty provisions do not bar a State from taxing profits attributable to a permanent establishment under its domestic law; obliges competent authorities to exchange obtainable information for implementing the Agreement or domestic tax laws; and provides that if a State later permits collection assistance with third States it will inform the other State and negotiate incorporation of collection assistance provisions into the Agreement.
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 must share obtainable tax information to implement the tax treaty and domestic laws.
The Protocol requires competent authorities to resolve indeterminate places of effective management by mutual agreement; confirms that treaty provisions do not bar a State from taxing profits attributable to a permanent establishment under its domestic law; obliges competent authorities to exchange obtainable information for implementing the Agreement or domestic tax laws; and provides that if a State later permits collection assistance with third States it will inform the other State and negotiate incorporation of collection assistance provisions into the Agreement.
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