Exchange of information obligations expanded under DTAA protocol, enabling cross-border tax information sharing with confidentiality safeguards and limited exceptions. The Protocol replaces Article 25 to require competent authorities to exchange foreseeably relevant tax information for administration or enforcement, mandates secrecy and restricted use of received information subject to authorisation for other uses, preserves limited exceptions based on domestic law or public policy, and obliges States to use their information-gathering measures to obtain requested information, including information held by banks or fiduciaries, even if the information is not needed for the requested State's own tax purposes.
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 obligations expanded under DTAA protocol, enabling cross-border tax information sharing with confidentiality safeguards and limited exceptions.
The Protocol replaces Article 25 to require competent authorities to exchange foreseeably relevant tax information for administration or enforcement, mandates secrecy and restricted use of received information subject to authorisation for other uses, preserves limited exceptions based on domestic law or public policy, and obliges States to use their information-gathering measures to obtain requested information, including information held by banks or fiduciaries, even if the information is not needed for the requested State's own tax purposes.
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