Double Taxation Agreement

For business information, annual reports, laws, ordinances, regulations and articles.

EXCHANGE OF INFORMATION
ARTICLE 26

126	Scope.
127.	Prevention of fiscal evasion.
127.1	Meaning of expressions ‘avoidance’ and ‘evasion’.
127.2	Avoidance not regarded as evasion till recently.
127.3	Doctrines of business purposes test and substance of transaction.
127.3-1	Business purpose test.
127.3-2	Doctrine of ‘substance’ of transaction.
127.4	Circumstances where evasion could be said to have taken place.
127.5	Fiscal nullity and tax evasion.
128.	Secrecy of Information exchange.
129.	Exceptions.