January 18, 2013
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Exchange of information: new guidelines require specific, non fishing requests and permit broad tax data sharing under confidentiality.
Guidelines adopt OECD/Global Forum request templates requiring separate, specific proformas per taxpayer-country pair and disallowing generic 'fishing expeditions'; requests may cover data on servers in either partner state and extend beyond income tax where treaties permit. Requesting states must specify the applicable limitation period and may be required to demonstrate foreseeable relevance; categories of permitted information include ownership, beneficiaries, accounting records, acquisition prices, tax returns and payments, beneficial ownership and transfer pricing details. The manual provides formats, allows spontaneous exchanges, cross-border examinations, joint audits, provisional measures to aid collection, and mandates confidentiality of exchanged information.