Exchange of information: Treaty requires mutual tax information exchange and use of information gathering measures between contracting states. Article 27 requires competent authorities to exchange information, including documents, necessary for implementing the Agreement and domestic tax laws; such information must be treated as secret and used only for assessment, collection, enforcement, prosecution or appeals, with limited disclosure to relevant persons or authorities and in public judicial proceedings. A State need not change its laws or provide unobtainable information or disclose trade or public policy sensitive secrets, but must use its information gathering measures to obtain requested information and cannot refuse solely because information is held by banks, financial institutions, nominees, agents, fiduciaries or concerns 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 mutual tax information exchange and use of information gathering measures between contracting states.
Article 27 requires competent authorities to exchange information, including documents, necessary for implementing the Agreement and domestic tax laws; such information must be treated as secret and used only for assessment, collection, enforcement, prosecution or appeals, with limited disclosure to relevant persons or authorities and in public judicial proceedings. A State need not change its laws or provide unobtainable information or disclose trade or public policy sensitive secrets, but must use its information gathering measures to obtain requested information and cannot refuse solely because information is held by banks, financial institutions, nominees, agents, fiduciaries or concerns ownership interests.
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