Assistance in the collection of taxes: mutual aid to prevent treaty benefit abuse while preserving domestic legal limits. Article 26A requires Contracting States to assist each other to prevent improper enjoyment of treaty tax benefits while preserving domestic legal and administrative limits. Assistance requires a certified document from the requesting State showing the sums are finally due and enforceable; that document must be rendered enforceable under the requested State's law. Recovery is effected according to the requested State's rules for similar tax debts, appeals on existence or amount remain with the requesting State's competent tribunal, and no assistance obligation forces measures contrary to a State's laws, administrative practice, sovereignty or public policy.
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Provisions expressly mentioned in the judgment/order text.
Assistance in the collection of taxes: mutual aid to prevent treaty benefit abuse while preserving domestic legal limits.
Article 26A requires Contracting States to assist each other to prevent improper enjoyment of treaty tax benefits while preserving domestic legal and administrative limits. Assistance requires a certified document from the requesting State showing the sums are finally due and enforceable; that document must be rendered enforceable under the requested State's law. Recovery is effected according to the requested State's rules for similar tax debts, appeals on existence or amount remain with the requesting State's competent tribunal, and no assistance obligation forces measures contrary to a State's laws, administrative practice, sovereignty or public policy.
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