Exchange of information: treaty requires sharing tax relevant documents with confidentiality and limited authorised use. The DTAA obliges competent authorities to exchange information foreseeably relevant to treaty implementation or domestic tax administration, including documents, subject to confidentiality and limited use for tax assessment, enforcement, appeals and oversight; other uses require mutual legal permission and supplying State authorisation. Limits permit refusal where compliance would contradict domestic law or practice, where information is unobtainable, or where disclosure would reveal trade or professional secrets or offend public policy, but do not allow refusal solely because information is held by banks, nominees, fiduciaries or relates to ownership interests.
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: treaty requires sharing tax relevant documents with confidentiality and limited authorised use.
The DTAA obliges competent authorities to exchange information foreseeably relevant to treaty implementation or domestic tax administration, including documents, subject to confidentiality and limited use for tax assessment, enforcement, appeals and oversight; other uses require mutual legal permission and supplying State authorisation. Limits permit refusal where compliance would contradict domestic law or practice, where information is unobtainable, or where disclosure would reveal trade or professional secrets or offend public policy, but do not allow refusal solely because information is held by banks, nominees, fiduciaries or relates to ownership interests.
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