Exchange of information enables cross-border tax assistance while preserving confidentiality and respecting lawful limitations on disclosure. Article 26 creates a reciprocal framework obliging competent authorities to exchange foreseeably relevant information for administering, assessing, enforcing, prosecuting, and adjudicating taxes, subject to confidentiality and use limits. Requested States must deploy information gathering measures even absent a domestic interest, cannot refuse solely because information is held by financial intermediaries, and may provide depositions and authenticated originals. Information received must be treated as secret and used only by tax officials and oversight persons, disclosure being limited to permitted judicial proceedings or with consent for mutual legal assistance; permissible limitations include adherence to domestic law, inability to obtain information, and protection of trade secrets or public policy.
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 cross-border tax assistance while preserving confidentiality and respecting lawful limitations on disclosure.
Article 26 creates a reciprocal framework obliging competent authorities to exchange foreseeably relevant information for administering, assessing, enforcing, prosecuting, and adjudicating taxes, subject to confidentiality and use limits. Requested States must deploy information gathering measures even absent a domestic interest, cannot refuse solely because information is held by financial intermediaries, and may provide depositions and authenticated originals. Information received must be treated as secret and used only by tax officials and oversight persons, disclosure being limited to permitted judicial proceedings or with consent for mutual legal assistance; permissible limitations include adherence to domestic law, inability to obtain information, and protection of trade secrets or public policy.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.