Exchange of information obligations ensure confidentiality and limited tax-use, subject to narrowly drawn exceptions. Article 26 provides for the exchange of information necessary to implement the Convention, requiring that received information be treated as secret and used only by persons or authorities concerned with assessment, collection, enforcement, prosecution, or appeals in relation to the covered taxes; disclosure is otherwise limited to public court proceedings or judicial decisions. It also excludes any obligation to take measures contrary to domestic law or practice, to provide information not obtainable under law or normal administration, or to disclose trade/business secrets or information contrary to public policy.
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 obligations ensure confidentiality and limited tax-use, subject to narrowly drawn exceptions.
Article 26 provides for the exchange of information necessary to implement the Convention, requiring that received information be treated as secret and used only by persons or authorities concerned with assessment, collection, enforcement, prosecution, or appeals in relation to the covered taxes; disclosure is otherwise limited to public court proceedings or judicial decisions. It also excludes any obligation to take measures contrary to domestic law or practice, to provide information not obtainable under law or normal administration, or to disclose trade/business secrets or information contrary to public policy.
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