Are the Confidentiality Obligations of Tax Authorities under Exchange of Information towards Taxpayers a “Treaty Benefit” for Purposes of the Principal Purpose Test?

Marius Pollitzer

doi:10.59403/1nxfsmm

Are the Confidentiality Obligations of Tax Authorities under Exchange of Information towards Taxpayers a “Treaty Benefit” for Purposes of the Principal Purpose Test?

Institute for European and International Law

Publication: Scientific journal › Journal article

Original language	English
Number of pages	8
Journal	Bulletin for International Taxation
Volume	78
Issue number	8
DOIs	https://doi.org/10.59403/1nxfsmm
Publication status	Published - 7 Aug 2024

Keywords

OECD Model Tax Convention
exchange of information
Principal Purpose Test
International Tax Law

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Cite this

@article{8e9d460060a74827b9285b99ed0ce95a,

title = "Are the Confidentiality Obligations of Tax Authorities under Exchange of Information towards Taxpayers a “Treaty Benefit” for Purposes of the Principal Purpose Test?",

keywords = "OECD Model Tax Convention, exchange of information, Principal Purpose Test, International Tax Law",

author = "Marius Pollitzer",

year = "2024",

month = aug,

day = "7",

doi = "10.59403/1nxfsmm",

language = "English",

volume = "78",

journal = "Bulletin for International Taxation",

issn = "1819-5490",