Agreement between the Government of the Republic of India and the Government of the Republic of Slovenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes - 90/2017 - Income Tax
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Exchange of information expanded: mutual tax information exchange and cross-border assistance in tax collection under amended protocol. The Amending Protocol replaces Article 26 with an expanded Exchange of Information clause obliging competent authorities to exchange foreseeably relevant tax information, require confidentiality and restrict use to tax purposes unless jointly authorized, while denying refusal based on bank secrecy and requiring use of information gathering measures even absent domestic interest. It also inserts an Assistance in the Collection of Taxes Article obliging requested States to accept and collect enforceable tax claims and to take conservancy measures under their laws, subject to specified limitations including public policy, domestic law variance, and disproportionate administrative burden.
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Provisions expressly mentioned in the judgment/order text.
Exchange of information expanded: mutual tax information exchange and cross-border assistance in tax collection under amended protocol.
The Amending Protocol replaces Article 26 with an expanded Exchange of Information clause obliging competent authorities to exchange foreseeably relevant tax information, require confidentiality and restrict use to tax purposes unless jointly authorized, while denying refusal based on bank secrecy and requiring use of information gathering measures even absent domestic interest. It also inserts an Assistance in the Collection of Taxes Article obliging requested States to accept and collect enforceable tax claims and to take conservancy measures under their laws, subject to specified limitations including public policy, domestic law variance, and disproportionate administrative burden.
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