Exchange of Information with Respect to MNE Groups Sample Clauses

Exchange of Information with Respect to MNE Groups. Pursuant to the provisions of Article 26 of the Convention, each Competent Authority intends to exchange with the other Competent Authority annually on an automatic basis the CbC Report received from each Reporting Entity that is resident for tax purposes in its jurisdiction, provided that, on the basis of the information provided in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting Entity are resident for tax purposes in the jurisdiction of the other Competent Authority, or are subject to tax with respect to the business carried out through a permanent establishment situated in the jurisdiction of the other Competent Authority.
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Exchange of Information with Respect to MNE Groups. 1. Pursuant to the provisions of Articles 6, 21 and 22 of the Convention, each Competent Authority will annually exchange on an automatic basis the CbC Report received from each Reporting Entity that is resident for tax purposes in its jurisdiction with all such other Competent Authorities of Jurisdictions with respect to which it has this Agreement in effect, and in which, on the basis of the information in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting Entity are either resident for tax purposes, or are subject to tax with respect to the business carried out through a permanent establishment. 2. Notwithstanding the previous paragraph, the Competent Authorities of the Jurisdictions that have indicated that they are to be listed as non-reciprocal jurisdictions on the basis of their notification pursuant to paragraph 1 b) of Section 8 will send CbC Reports pursuant to paragraph 1, but will not receive CbC Reports under this Agreement. Competent Authorities of Jurisdictions that are not listed as non-reciprocal Jurisdictions will both send and receive the information specified in paragraph 1. Competent Authorities will, however, not send such information to Competent Authorities of the Jurisdictions included in the aforementioned list of non-reciprocal Jurisdictions.
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Exchange of Information with Respect to MNE Groups. 1. Pursuant to the provisions of Article 28 of the Convention, the Competent Authority of each Party shall exchange with the Competent Authority of the other Party annually, on an automatic basis, the CbC Report received from each Reporting Entity that is resident for tax purposes in its jurisdiction, provided that, on the basis of the information provided in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting Entity are resident for tax purposes in the jurisdiction of the other Competent Authority, or are subject to tax with respect to the business carried out through a permanent establishment situated in the jurisdiction of the other Competent Authority. 2. The Competent Authorities shall sign an arrangement under the mutual agreement procedure provided for in Article 27 of the Convention (the “Arrangement”), which shall: a) establish the procedure for the time and manner of the exchange of the CbC Reports described in paragraph 1 of Article 2 of this Agreement; b) set forth the procedure for collaboration on transmission and errors in the exchange of the CbC Reports described in paragraph 1 of Article 2 of this Agreement; c) provide for confidentiality, data safeguards, and appropriate use with respect to the CbC Reports described in paragraph 1 of Article 2 of this Agreement; d) provide for consultations with respect to the CbC Reports described in paragraph 1 of Article 2 of this Agreement; and e) provide for modifications to, and term of, the Arrangement.
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Exchange of Information with Respect to MNE Groups. Pursuant to the provisions of Article 3 of the TIEA, the Bermuda Competent Authority intends to exchange with the United States Competent Authority annually on an automatic basis the CbC Report received from each Reporting Entity that is resident for tax purposes in Bermuda, provided that, on the basis of the information provided in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting Entity are resident for tax purposes in the United States, or are subject to tax with respect to the business carried out through a permanent establishment situated in the United States.
Sample 1
Exchange of Information with Respect to MNE Groups. Pursuant to the provisions of Article 6 of the TIEA, the Cayman Islands Competent Authority intends to exchange with the United States Competent Authority annually on an automatic basis the CbC Report received from each Reporting Entity that is resident for tax purposes in the Cayman Islands, provided that, on the basis of the information provided in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting Entity are resident for tax purposes in the United States, or are subject to tax with respect to the business carried out through a permanent establishment situated in the United States.
Sample 1
Exchange of Information with Respect to MNE Groups. Pursuant to the provisions of Paragraph 4 of the Arrangement, the Competent Authority of the Cayman Islands will annually exchange with the Competent Authority of Guernsey on an automatic basis the CbC Report received from each Reporting Entity that is resident for tax purposes in the Cayman Islands, provided that, on the basis of the information provided in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting Entity are resident for tax purposes in Guernsey or are subject to tax with respect to the business carried out through a permanent establishment situated in Guernsey.
Sample 1
Exchange of Information with Respect to MNE Groups. Pursuant to the provisions of Paragraph 8 of the TIEA, the Competent Authority of the British Virgin Islands will annually exchange with the Competent Authority of the Isle of Man on an automatic basis the CbC Report received from each Reporting Entity that is resident for tax purposes in the British Virgin Islands, provided that, on the basis of the information provided in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting Entity are resident for tax purposes in the Isle of Man or are subject to tax with respect to the business carried out through a permanent establishment situated in the Isle of Man.
Sample 1
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Exchange of Information with Respect to MNE Groups. Pursuant to the provisions of Paragraph 8 of the TIEA, the Competent Authority of the Turks and Caicos Islands will annually exchange with the Competent Authority of the Isle of Man on an automatic basis the CbC Report received from each Reporting Entity that is resident for tax purposes in the Turks and Caicos Islands, provided that, on the basis of the information provided in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting Entity are resident for tax purposes in the Isle of Man or are subject to tax with respect to the business carried out through a permanent establishment situated in the Isle of Man.
Sample 1

Related to Exchange of Information with Respect to MNE Groups

  • Exchange of Information 1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2. 2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; (b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public). 4. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information. 5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person.

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