Tax examination abroad: cross border interviews and presence allowed with consent and requested State control over procedures. Article 28A permits representatives of a requesting State to enter the requested State to interview individuals and examine records with the prior written consent of the persons concerned and after notifying the requested State of time and place. It also permits representatives to be present during parts of tax examinations if the requested State agrees, requires the requested State to notify details and procedures, and confirms that all decisions on conducting the examination rest with the requested State.
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.
Tax examination abroad: cross border interviews and presence allowed with consent and requested State control over procedures.
Article 28A permits representatives of a requesting State to enter the requested State to interview individuals and examine records with the prior written consent of the persons concerned and after notifying the requested State of time and place. It also permits representatives to be present during parts of tax examinations if the requested State agrees, requires the requested State to notify details and procedures, and confirms that all decisions on conducting the examination rest with the requested State.
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