Exchange of Information requests must use the revised Form A and be routed to the appropriate competent authority for processing. Requests for exchange of information must be submitted in the revised Form A and routed to the designated Competent Authority (FT&TR I or FT&TR II) by jurisdiction; Part I records taxpayer and requesting officers for internal use and Part II, modelled on the OECD template, is sent to foreign authorities and must set out legal basis, background, specific information requests, grounds for believing the information is held abroad, urgency, confidentiality undertakings and any request to refrain from notifying the taxpayer. Requests must demonstrate foreseeable relevance, exhaustion of domestic means or disproportionate difficulty, and comply with row wise instructions or risk return as defective.
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 requests must use the revised Form A and be routed to the appropriate competent authority for processing.
Requests for exchange of information must be submitted in the revised Form A and routed to the designated Competent Authority (FT&TR I or FT&TR II) by jurisdiction; Part I records taxpayer and requesting officers for internal use and Part II, modelled on the OECD template, is sent to foreign authorities and must set out legal basis, background, specific information requests, grounds for believing the information is held abroad, urgency, confidentiality undertakings and any request to refrain from notifying the taxpayer. Requests must demonstrate foreseeable relevance, exhaustion of domestic means or disproportionate difficulty, and comply with row wise instructions or risk return as defective.
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