Exchange of information obligations require foreseeable tax data sharing with confidentiality and limited use safeguards. Article 28 requires competent authorities to exchange information foreseeably relevant to implementing the DTAA or administering domestic tax laws, subject to confidentiality: received information is treated as secret and disclosed only to authorized persons or authorities for assessment, collection, enforcement, prosecution, appeals or oversight and may be used only for those purposes (except where both States' laws permit other uses). Limitations prevent obligations to alter domestic practices, to provide unobtainable information, or to disclose trade or public policy sensitive secrets. States must employ information gathering measures to obtain requested data and cannot refuse solely because information is held by banks, financial institutions, nominees 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 obligations require foreseeable tax data sharing with confidentiality and limited use safeguards.
Article 28 requires competent authorities to exchange information foreseeably relevant to implementing the DTAA or administering domestic tax laws, subject to confidentiality: received information is treated as secret and disclosed only to authorized persons or authorities for assessment, collection, enforcement, prosecution, appeals or oversight and may be used only for those purposes (except where both States' laws permit other uses). Limitations prevent obligations to alter domestic practices, to provide unobtainable information, or to disclose trade or public policy sensitive secrets. States must employ information gathering measures to obtain requested data and cannot refuse solely because information is held by banks, financial institutions, nominees or fiduciaries.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
