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Exchange of information: reciprocal tax information sharing with confidentiality and limited authorised use. Article 27 provides for reciprocal exchange of information, including documents, that is foreseeably relevant to the Convention or to administering or enforcing domestic tax laws; exchanged information must be kept secret and used only for tax assessment, collection, enforcement, prosecution, appeals or oversight, except where both States' laws and the supplying authority permit other uses. States are not required to act contrary to their laws or practice, to provide unobtainable information, or to disclose trade or professional secrets or information contrary to public policy. Subject to these limits, States must use their information gathering measures to obtain requested information and may not refuse solely because the information is held by banks, 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: reciprocal tax information sharing with confidentiality and limited authorised use.
Article 27 provides for reciprocal exchange of information, including documents, that is foreseeably relevant to the Convention or to administering or enforcing domestic tax laws; exchanged information must be kept secret and used only for tax assessment, collection, enforcement, prosecution, appeals or oversight, except where both States' laws and the supplying authority permit other uses. States are not required to act contrary to their laws or practice, to provide unobtainable information, or to disclose trade or professional secrets or information contrary to public policy. Subject to these limits, States must use their information gathering measures to obtain requested information and may not refuse solely because the information is held by banks, nominees or fiduciaries.
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