INFORMATION SUBJECT TO EXCHANGE. This Agreement applies to any information in the possession of any signatory state that could reasonably be considered useful to other signatory states in tax administration, including taxpayer compliance measures and litigation. Such information includes, but is not limited to, (1) lists of taxpayers or potential taxpayers including identifying data; (2) tax or information returns or documents including supporting schedules, attachments, and lists; (3) nexus information and questionnaires; (4) research and revenue estimating materials; (5) audit reports and other information regarding or acquired through audit; (6) contingent tax liability and tax reserve work papers; (7) proprietary taxpayer information, including without limitation, information on inter- company pricing decisions, intellectual property values and profits, comparable industry profits, risk factors, capital costs, employee compensation, division and subsidiary profits, salaries and benefits, overhead charges, interest charges, transfer pricing reports and recommendations, comparable profits, charges, royalty rates, investment decisions, business location decisions, transfers of personnel, transfers of property, collection and enforcement activities, responses to interrogatories, depositions, any other documents with respect to private letter ruling requests, protests, appeals and criminal tax matters with respect to any taxpayer, potential taxpayer, or group of taxpayers or potential taxpayers; and (8) any other information eligible to be exchanged pursuant to laws of the signatory states.
Appears in 2 contracts
Samples: Participation Commitment and Exchange of Information Agreement, Participation Commitment and Exchange of Information Agreement
INFORMATION SUBJECT TO EXCHANGE. This Agreement applies to any information in the possession of any signatory state that which could reasonably be considered useful to other signatory states in tax administration, including taxpayer compliance measures and litigation. Such information includes, but is not limited to, (1) lists of taxpayers or potential taxpayers including identifying data; (2) tax or information returns or documents including supporting schedules, attachments, and lists; (3) nexus information and questionnaires; (4) research and revenue estimating materials; (5) audit reports and other information regarding or acquired through audit; (6) contingent tax liability and tax reserve work papers; (7) proprietary taxpayer information, including without limitation, information on inter- company pricing decisions, intellectual property values and profits, comparable industry profits, risk factors, capital costs, employee compensation, division and subsidiary profits, salaries and benefits, overhead charges, interest charges, transfer pricing reports and recommendations, comparable profits, charges, royalty rates, investment decisions, business location decisions, transfers of personnel, transfers of property, collection and enforcement activities, responses to interrogatories, depositions, any other documents with respect to private letter ruling requests, protests, appeals and criminal tax matters with respect to any taxpayer, potential taxpayer, or group of taxpayers or potential taxpayers; and (8) any other information eligible to be exchanged pursuant to laws of the signatory states.
Appears in 2 contracts
Samples: Participation Commitment and Exchange of Information Agreement, Participation Commitment and Exchange of Information Agreement
INFORMATION SUBJECT TO EXCHANGE. This Agreement agreement applies to any information in the possession of any signatory state that which could reasonably be considered useful to other signatory states in tax administration, including taxpayer compliance measures and litigation. Such information includes, but is not limited to, (1) lists of taxpayers or potential taxpayers including identifying data; (2) tax or information returns or documents including supporting schedules, attachments, and lists; (3) nexus information and questionnaires; (4) research and revenue estimating materials; (5) audit reports and other information regarding or acquired through audit; (6) contingent tax liability and tax reserve work papers; (7) proprietary taxpayer information, including without limitation, information on inter- company pricing decisions, intellectual property values and profits, comparable industry profits, risk factors, capital costs, employee compensation, division and subsidiary profits, salaries and benefits, overhead charges, interest charges, transfer pricing reports and recommendations, comparable profits, charges, royalty rates, investment decisions, business location decisions, transfers of personnel, transfers of property, collection and enforcement activities, responses to interrogatories, depositions, any other documents with respect to private letter ruling requests, protests, appeals and criminal tax matters with respect to any taxpayer, potential taxpayer, or group of taxpayers or potential taxpayers; and (8) any other information eligible to be exchanged pursuant to laws of the signatory states.
Appears in 1 contract
Samples: Exchange of Information Agreement