Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income Article 42
After issuing a Certificate of Residence according to Article 38, the tax collection authority shall create a file for the relevant income data of the other Contracting State provided by the applicant. At the end of the year, all of these files created by such tax collection authority shall be delivered in bulk to the Fiscal Information Agency, Ministry of Finance for data matching.For each case that has been approved under Articles 23 to 27, a file shall be made by the relevant tax collection authority, and be delivered in bulk to the Fiscal Information Agency, Ministry of Finance at the end of the year for data matching.