Exchange of information requires mutual information gathering, confidentiality, and limited disclosure for tax administration and enforcement. The treaty requires competent authorities to exchange foreseeably relevant information, including documents, for tax administration and enforcement; such information is to be kept secret and used only by tax and oversight authorities, with disclosure in public judicial proceedings permitted. Use for other purposes needs legal permissibility in both States and authorization by the supplying State. States need not contravene their laws or supply unobtainable information or disclose protected trade secrets or matters contrary to public policy. Requested States must nevertheless use information gathering measures to obtain information even without a domestic interest, and cannot refuse solely because information is held by banks, 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 requires mutual information gathering, confidentiality, and limited disclosure for tax administration and enforcement.
The treaty requires competent authorities to exchange foreseeably relevant information, including documents, for tax administration and enforcement; such information is to be kept secret and used only by tax and oversight authorities, with disclosure in public judicial proceedings permitted. Use for other purposes needs legal permissibility in both States and authorization by the supplying State. States need not contravene their laws or supply unobtainable information or disclose protected trade secrets or matters contrary to public policy. Requested States must nevertheless use information gathering measures to obtain information even without a domestic interest, and cannot refuse solely because information is held by banks, nominees, agents, fiduciaries, or concerns ownership interests.
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