Exchange of information requires sharing tax-relevant data between competent authorities while maintaining secrecy and limited-use protections. Competent authorities shall exchange foreseeably relevant information for implementing the Convention and administering or enforcing domestic tax laws; exchanged information must be treated as secret and disclosed only to persons or authorities concerned with tax assessment, collection, enforcement, prosecution, appeals or oversight, and used solely for those purposes, with judicial disclosure permitted. A State is not required to act contrary to its laws, supply unobtainable information, or disclose trade or public-policy-protected secrets, but must use its information-gathering measures to obtain requested information and may not refuse solely because information is held by banks, nominees or fiduciaries or relates to 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 sharing tax-relevant data between competent authorities while maintaining secrecy and limited-use protections.
Competent authorities shall exchange foreseeably relevant information for implementing the Convention and administering or enforcing domestic tax laws; exchanged information must be treated as secret and disclosed only to persons or authorities concerned with tax assessment, collection, enforcement, prosecution, appeals or oversight, and used solely for those purposes, with judicial disclosure permitted. A State is not required to act contrary to its laws, supply unobtainable information, or disclose trade or public-policy-protected secrets, but must use its information-gathering measures to obtain requested information and may not refuse solely because information is held by banks, nominees or fiduciaries or relates to ownership interests.
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