January 26, 2011
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Exchange of information obligations expanded to enable cross-border tax investigations and strengthen offshore asset transparency.
The strategy combines international engagement to remove bank secrecy and expand information exchange, treaty negotiations to modify DTAAs and sign TIEAs permitting banking information and tax examinations abroad, and legislative measures including widened PMLA predicate offences and Direct Taxes Code provisions (GAAR, CFC rules, expanded wealth tax definitions and mandatory reporting). Institutional reforms create overseas income-tax units, a dedicated Exchange of Information unit and technology platforms, while transfer pricing rules are to be revised and specialised officer training and incentives provided for effective implementation.