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Extra resources for Implementing the Tax Transparency Standards: A Handbook for Assessors and Jurisdictions

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The PRG then discusses the issues raised in the report, focusing on the substantive outstanding issues. As a matter of good practice, delegations should not raise comments that they have not raised in writing. However, should a delegation wish to bring up a new issue, it should, if possible, inform the PRG/Secretariat in advance of the discussion. The PRG should give careful consideration to the views of the assessors and the jurisdiction when deciding on the wording, as well as taking into account the need to ensure consistency between reports.

The questionnaire for the assessed jurisdiction will have a standard format. It will generally be supplemented by jurisdiction-specific questions. These may include questions regarding specific institutions or procedures in the assessed jurisdiction, issues raised by other Global Forum members (see above) and (in the case of a Phase 2 review) issues arising from an earlier Phase 1 report. 19. The standard questionnaire for Phase 2 will include requests for quantitative data allowing meaningful review of the treatment of requests and the period between request and response, and qualitative data in order to help assess the reliability and relevance of information provided to the requesting parties.

Most double taxation agreements are based on the OECD Model Tax Convention. B. Article 26 of the Model Tax Conventions and their Commentary 11. The Model Tax Convention is the most widely accepted legal basis for double taxation agreements. More than 3000 bilateral treaties are based on the Model Tax Convention. Article 26 of the Model Tax Convention in turn provides the most widely accepted legal basis for bilateral exchange of information for tax purposes. 12. In 2002, the OECD Committee on Fiscal Affairs (CFA) undertook a comprehensive review of Article 26 of the Model Tax Convention and its Commentary to ensure that they reflected current jurisdiction practices and to take account of the development of the Model Agreement by the Global Forum Working Group.

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