Exchange of information: tax authorities must obtain and share foreseeably relevant information, subject to narrow confidentiality exceptions. Authorities must exchange information foreseeably relevant for applying the Agreement or administering domestic tax laws; such information is to be kept secret and used only by persons or bodies responsible for assessment, collection, enforcement, prosecution, appeals or oversight, with permitted disclosure in court proceedings. A State need not act contrary to its laws or administrative practice, supply unobtainable information, or disclose trade secrets or information against public policy, but must nonetheless use information gathering measures to obtain requested information even without domestic interest, and may not refuse solely because the information is held by banks, financial institutions, nominees or fiduciaries.
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: tax authorities must obtain and share foreseeably relevant information, subject to narrow confidentiality exceptions.
Authorities must exchange information foreseeably relevant for applying the Agreement or administering domestic tax laws; such information is to be kept secret and used only by persons or bodies responsible for assessment, collection, enforcement, prosecution, appeals or oversight, with permitted disclosure in court proceedings. A State need not act contrary to its laws or administrative practice, supply unobtainable information, or disclose trade secrets or information against public policy, but must nonetheless use information gathering measures to obtain requested information even without domestic interest, and may not refuse solely because the information is held by banks, financial institutions, nominees or fiduciaries.
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