standards by means of the implementation of an international treaty since the information obtained can be used exclusively for the determination of the tax and may not be shared with other persons other than the competent authorities in the administration of taxes.
Regarding the costs of the exchange of information the Convention does not consider which of the parties assume the same, therefore in practice the tax administrations solve the situation by mutual agreement, finding ways to reduce costs for both parties.
6. EXCHANGE OF INFORMATION ON REQUEST - OECD GUIDE
Prior to referral of the request for information on a person or company under verification, the country that performs the same must exhaust the means to obtain information in its own country at a reasonable cost either through public information on the Internet, information that diplomatic missions may have in the country or anything that may be obtained through the base developed by the OECD as reference guide on sources of public information abroad available at www.oecd.org/taxation for the competent authorities of the public revenue administrations. Having fulfilled this preliminary step, a written request containing at least the information described in the Manual for the Exchange of Information of the OECD, “Exchange of information on request� module. It must also include a statement concerning the reciprocity clause as set out in the general part of the manual. When the requested country receives the request, it acknowledges receipt and verifies that it complies with all legal requirements, it is forwarded by the competent authority, including all the information needed to be answered and the information requested falls within the provisions of the Convention. If the request is not valid for the requested country, the applicant must be informed, stating the reasons by which it is considered that the request cannot be answered. If on the other hand, the application complies with all the formalities and requirements to be answered, it must be investigated promptly.
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Once a request for information is accepted and transacted it must be answered with the greatest urgency by attaching further information or documentation, which has not even been requested, however, it is considered of relevance pursuant to the statements of the request filed by the requesting country. Deadlines for processing are not set in the Convention, however, the OECD exchange of information guide suggests it should be answered within 90 days of the receipt, by informing the requesting party when this term is not sufficient. On this regard, the internal regulations regarding checks must also be observed, taking into account the date in which the information will no longer be useful to the applicant country, if such date was informed in the request for information. In the same order, IG 894 establishes that Argentina shall observe the time limits laid down in specific agreements for the exchange of information which have a term of 3 and 6 months depending on if the information is available or not internally. There are no internal rules in Canada to comply with the procedure for the exchange of information, the time limits to comply are not clearly established, Argentina now has IG 894/2010, however, no information was obtained to indicate that there are problems or inconveniences caused by delays in the processing of applications, therefore, the objective of collaboration and international transparency between administrations prevails.
Tax Administration Review CIAT/AEAT/IEF No. 30