Exchange of information enables tax authorities to obtain foreseeably relevant information for tax administration, subject to secrecy and narrow exceptions. Competent authorities must exchange foreseeably relevant information and documents for carrying out the Convention or domestic tax administration; such information is to be treated as secret and disclosed only to persons or authorities concerned with assessment, collection, enforcement, prosecution, appeals or oversight, and may be used only for those purposes unless both States' laws permit other uses and the supplying authority authorises them. The requested State must use its information gathering measures even absent domestic interest, subject to exceptions for legal impossibility, unobtainable information, trade secrets and public policy, but not solely because information is held by financial intermediaries 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 enables tax authorities to obtain foreseeably relevant information for tax administration, subject to secrecy and narrow exceptions.
Competent authorities must exchange foreseeably relevant information and documents for carrying out the Convention or domestic tax administration; such information is to be treated as secret and disclosed only to persons or authorities concerned with assessment, collection, enforcement, prosecution, appeals or oversight, and may be used only for those purposes unless both States' laws permit other uses and the supplying authority authorises them. The requested State must use its information gathering measures even absent domestic interest, subject to exceptions for legal impossibility, unobtainable information, trade secrets and public policy, but not solely because information is held by financial intermediaries or relates to ownership interests.
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