Exchange of information: competent authorities must share foreseeably relevant tax information for administration and enforcement. Article 26 requires competent authorities to exchange information foreseeably relevant for implementing the Convention or administering and enforcing domestic tax laws, with received information treated as secret and disclosed only to persons or authorities concerned with assessment, collection, enforcement, prosecution, appeals, or oversight and used only for those purposes unless both States permit other uses and the supplying authority authorises them; limits permit no requirement to act contrary to domestic law, to provide unobtainable information, or to disclose trade secrets or information contrary to public policy, while obliging States to use information gathering measures even absent domestic interest and prohibiting refusal solely because information is held by banks 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: competent authorities must share foreseeably relevant tax information for administration and enforcement.
Article 26 requires competent authorities to exchange information foreseeably relevant for implementing the Convention or administering and enforcing domestic tax laws, with received information treated as secret and disclosed only to persons or authorities concerned with assessment, collection, enforcement, prosecution, appeals, or oversight and used only for those purposes unless both States permit other uses and the supplying authority authorises them; limits permit no requirement to act contrary to domestic law, to provide unobtainable information, or to disclose trade secrets or information contrary to public policy, while obliging States to use information gathering measures even absent domestic interest and prohibiting refusal solely because information is held by banks or fiduciaries.
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