Assistance in collection of taxes: mutual enforcement and conservancy measures under the DTAA enabling cross border tax recovery. Article 28 provides that Contracting States shall accept and collect each other's revenue claims-including taxes, interest, penalties and collection costs-at the request of the competent authority and apply their own domestic enforcement and conservancy laws as if the claim were their own. The Article permits taking conservancy measures and interim asset freezing within domestic legal limits, requires notification if the claim ceases to qualify, reserves adjudication on existence or amount to the requesting State's courts or bodies, and limits assistance where it would conflict with domestic law, public policy, insufficient prior collection efforts, or impose disproportionate administrative burden.
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Provisions expressly mentioned in the judgment/order text.
Assistance in collection of taxes: mutual enforcement and conservancy measures under the DTAA enabling cross border tax recovery.
Article 28 provides that Contracting States shall accept and collect each other's revenue claims-including taxes, interest, penalties and collection costs-at the request of the competent authority and apply their own domestic enforcement and conservancy laws as if the claim were their own. The Article permits taking conservancy measures and interim asset freezing within domestic legal limits, requires notification if the claim ceases to qualify, reserves adjudication on existence or amount to the requesting State's courts or bodies, and limits assistance where it would conflict with domestic law, public policy, insufficient prior collection efforts, or impose disproportionate administrative burden.
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