Systemic failure: treaty partners suspending automatic information exchange or persistently withholding multinational group reports triggers compliance consequences. For section 286(9)(I) purposes, systemic failure occurs where a treaty partner, though bound to exchange reports with India, either suspends automatic ... Summary
Systemic failure: treaty partners suspending automatic information exchange or persistently withholding multinational group reports triggers compliance consequences.
For section 286(9)(I) purposes, systemic failure occurs where a treaty partner, though bound to exchange reports with India, either suspends automatic exchange in violation of the agreement or persistently fails to provide automatically to India reports it holds about any international group with a constituent entity resident in India.
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