This Lesson 21 equips learners to analyze tax debts that arise or behave differently because of (i) audit/reassessment mechanics, (ii) voluntary disclosure programs, (iii) cross‑border enforcement and treaty mechanisms, (iv) public‑sector institutional rules, and (v) NGO/exempt‑entity regimes. Across jurisdictions, the debt amount is rarely just “tax”: it typically includes interest, penalties/administrative fines, and sometimes collection costs, which (notably) are explicitly included in “tax claim” definitions in cross‑border recovery instruments.

Suggested class format (instructor-ready): a 180‑minute session plus a short pre‑read. The session is designed for mixed cohorts (tax compliance, controversy, accounting, legal). The flow moves from universal debt principles → the five “special situations” → comparative jurisdictional contrasts → worked computations → practice via case studies, role-play, and assessment.

Learning objectives (measurable): By the end of Lesson 21, learners should be able to 1) Distinguish audit-driven vs self-corrected/disclosure-driven liabilities and map them to procedural steps (proposal → assessment → appeal → collection). 2) Evaluate whether a fact pattern is “prompted vs unprompted” (where relevant) and predict the penalty range and disclosure consequences. 3) Identify cross‑border tools (EOI, automatic exchange, MAP, mutual assistance in recovery/service) and the conditions/limits for using them. 4) Diagnose government‑entity and NGO/exempt‑entity debt risks (withholding/payroll, VAT/GST, revocation/UBI/UBIT) and design mitigation controls. 5) Compute a tax debt under simplified assumptions (tax + penalty + interest) and explain sensitivities (interest basis, compounding, time windows, relief).

Instructor pre‑read assignment (30–45 minutes): Learners skim (a) “audit/examination” overview, (b) one voluntary disclosure guidance doc, and (c) one cross‑border assistance instrument excerpt. Recommended starting set: IRS Pub. 3498 (examination process); HMRC digital disclosure service guide; OECD/Council of Europe Convention excerpts (Articles 4, 11, 17).

Assumptions noted upfront (to disclose to students): This lesson is jurisdiction‑agnostic and uses “anchor jurisdictions” for contrast (U.S., U.K., Canada, Australia, Germany/EU). Where the law is rate‑driven (interest, penalty %, limitation periods), worked problems use simplified numeric assumptions and explicitly label where students must substitute local statutory rates. Examples do not constitute legal advice.

A “tax debt” is best taught as a bundle of legal components and procedural statuses, not a single number.

Debt components (conceptual decomposition): “Tax principal” + “interest” + “penalties/fines” + “collection costs/fees.” International recovery frameworks often define a recoverable tax claim to include tax, interest, related administrative fines, and costs incidental to recovery.

Assessment and finality (why “status” matters): Audit activity commonly produces a proposed adjustment (proposal stage) which later becomes an assessment/reassessment (enforceable stage). IRS examination guidance emphasizes that examinations determine whether items were reported accurately and includes post‑examination appeal and payment procedures. In Canada, CRA “business audits” describe examining books and records to confirm amounts filed, and audit outcomes can drive reassessments that generate collectible balances.

Interest as a statutory consequence of time: Interest typically runs from a legally defined due date until payment. In the U.S., interest on underpayment is imposed by statute and regulations. In the U.K., HMRC interest rates are legislated and linked to the Bank of England base rate; late payment interest is set at base rate + 4% from 6 April 2025 (per HMRC guidance). In Australia, the General Interest Charge (GIC) applies to unpaid tax liabilities and is worked out daily on a compounding basis, making timing effects more pronounced in calculations. In Canada, the CRA publishes prescribed interest rates for amounts owed and for amounts the CRA owes—useful for realistic debt projections in disputes and payment planning. In Germany (civil law example), statutory interest regimes can start later than the filing year; for example AO §233a provides that interest on certain tax differences begins 15 months after the end of the calendar year in which the tax arose.

Penalties: behavior‑based and disclosure‑sensitive: A core teaching point is that penalties can be functionally negotiable within statutory ranges via disclosure quality. In the U.K., HMRC’s Compliance Handbook shows maxima/minima by behavior and distinguishes unprompted vs prompted disclosures; careless inaccuracies can reach a 0% minimum (i.e., reducible to nil) if unprompted.

Appeals and collection can run in parallel: Many systems require proactive decisions about paying while disputing. ATO objection guidance explicitly includes the step to pay the debt by the due date as part of the objection checklist, highlighting the practical separation between disputing correctness and managing collection exposure.

Debt arising from audits (and compliance checks) Audit-driven debt is distinguished by (i) information‑gathering powers, (ii) a staged path from proposed adjustments to enforceable assessments, and (iii) time‑boxed appeal windows. IRS examination guidance frames audits as examinations that may be correspondence, office, or field based, with procedural steps before/during/after examination. In the U.K., HMRC describes what happens during a compliance check and available help/support, making it a good “process map” source for teaching.

Key analytical moves students should learn: Classify the issue type (income omission, deduction support failure, withholding failure, VAT/GST position, transfer pricing). Then separate (a) principal tax computation from (b) penalty basis (behavior + disclosure + offshore multipliers where relevant) and (c) interest clock rules.

Debt arising from voluntary disclosures Voluntary disclosure regimes often trade increasing certainty and reduced punitive outcomes for speed, completeness, and payment.

Anchor examples for teaching:

U.K. Digital Disclosure Service (DDS): DDS is used for several taxes but not VAT errors (VAT has separate correction mechanisms). It requires “notify,” then “disclose,” and the disclosure must be submitted within 90 days of HMRC acknowledging the notification; payment is expected by the same deadline or payment arrangements must be made.

Canada CRA VDP (IC00‑1R7, effective for applications received on/after Oct. 1, 2025): VDP may provide penalty relief, interest relief, and “no referral for criminal prosecution” if relief is granted. Eligibility conditions include that the disclosure relates to a year at least one year past the filing due date and includes an error/omission with applicable interest/penalties; payment (or a payment arrangement request) is required for estimated tax owing where applicable. IC00‑1R7 also describes a two‑level relief model: unprompted (general) relief typically includes 75% interest relief and 100% penalty relief, while prompted (partial) relief typically includes 25% interest relief and up to 100% penalty relief.

Australia ATO voluntary disclosures: ATO requires voluntary disclosures to be made in an approved form (with different lodgment options depending on timing and nature) and discusses penalties/interest and reductions for voluntary corrections.

U.S. (IRS Criminal Investigation) Voluntary Disclosure Practice (VDP): IRS CI describes circumstances that make a taxpayer ineligible for the VDP pathway, including having a civil examination or criminal investigation commenced, or having the IRS receive information from third parties about the noncompliance.

Debt involving cross-border taxpayers Cross‑border debt’s distinguishing features are information asymmetry, treaty constraints, and multi‑authority resolution options.

Teaching anchor: the Convention on Mutual Administrative Assistance in Tax Matters (OECD/Council of Europe). Its provisions are unusually explicit for classroom use:

Information exchange standard: Parties exchange information that is “foreseeably relevant” to assessment/collection and to recovery/enforcement of tax claims.

Assistance in recovery: On request, the requested state takes steps to recover tax claims “as if they were its own,” subject to conditions; generally, recovery assistance applies only to claims enforceable in the applicant state and (often) not contested, with an additional finality condition when the debtor is not resident in the applicant state. The Convention includes a hard outer limit: the requested state is not obliged to comply with a recovery request submitted after 15 years from the date of the original enforceable instrument.

Service of documents: Requested states serve documents emanating from the applicant state; service can be direct by post, and translation rules are addressed.

Cross‑border taxpayers also face dispute resolution tools beyond domestic appeals:

Mutual Agreement Procedure (MAP): The OECD publishes MAP profiles with competent authority details and domestic MAP guidance, supporting transparency about how to request relief from double taxation.

U.S. competent authority assistance/MAP: IRS guidance states that U.S. treaty residents may request competent authority assistance when actions of one/both treaty countries cause taxation inconsistent with the treaty, and IRS provides an overview of the MAP process.

U.K. competent authority process: HMRC’s International Manual instructs taxpayers to provide a full fact statement and relevant correspondence when invoking U.K. competent authority intervention.

Cross‑border detection and “new information” risk: Automatic exchange regimes (e.g., CRS) drive many offshore “discovery” events. OECD CRS materials describe automatic annual exchange of financial account information between jurisdictions (a key driver of prompted vs unprompted timing in offshore corrections).

Cross‑border mobility consequences (illustrative common-law example): In the U.S., tax debt can affect passports: IRS explains that under IRC §7345, taxpayers with “seriously delinquent tax debts” can be certified to the State Department for passport‑related actions.

Debt involving government institutions Government bodies often occupy special tax positions—either as non‑taxable for certain activities or as high‑risk withholding/VAT/GST remitters for payroll and procurement.

Useful teaching contrasts:

Payroll/withholding obligations still exist: IRS provides a dedicated “Federal, state and local governments” resource area and specifically addresses employment taxes for government entities—useful for showing that “public” does not mean “non‑taxpayer” for all tax types.

VAT/GST status may differ by function: EU VAT rules provide that states and other public-law bodies are not regarded as taxable persons for activities engaged in as public authorities (Article 13), which creates boundary disputes when public bodies also engage in commercial activities.

Refund/rebate mechanisms can invert “debt” logic: HMRC’s VAT Government and Public Bodies manual discusses “Section 33 bodies” and refund arrangements—important for teaching that public bodies may recover VAT in ways private bodies cannot, affecting net liability and debt risk.

Public service body rebates: CRA explains GST/HST “public service bodies’ rebate” eligibility, including charities and certain public service bodies—again emphasizing that public/charitable status often changes VAT/GST incidence and refundability, shaping net debt.

Debt involving NGOs and exempt entities Two recurring patterns create special debt outcomes: (i) loss of exemption/registration and (ii) taxation of non‑exempt streams (unrelated business income; payroll; VAT/GST).

Anchor rules (highly teachable):

Automatic revocation for non‑filing (U.S.): IRS states it publishes a list of organizations automatically revoked for failing to file required Form 990-series returns/notices for three consecutive years.

Unrelated business income tax (U.S.): IRS explains that an exempt organization with $1,000 or more of gross income from an unrelated business must file Form 990‑T, and that this is in addition to the annual information return obligation.

Revocation consequences (Canada): CRA provides guidance on revoking registered status and explicitly references “revocation tax” and the T2046 return, illustrating that “exempt today” can convert into “taxable + special exit tax” tomorrow.

Charities’ tax obligations (U.K.): GOV.UK provides detailed tax guidance and relief overviews for charities, supporting teaching around “relief is conditional on governance and compliance.”

The following tables are designed to function as classroom handouts (printable) and as a basis for “compare-and-contrast” discussion.

Appeals/objection windows snapshot (selected)

| Jurisdiction | “Trigger” event taught in class | Typical deadline highlighted | Primary source(s) | |---|---|---| | United States | Statutory Notice of Deficiency (“90‑day letter”) | Petition deadline framed as 90 days | | | United Kingdom | Appeal to tax tribunal | Usually 30 days from decision letter date | | | Canada | Notice of assessment/determination (income tax objection rights) | Often 90 days; for individuals, time limit can be the later of specific dates (see CRA guidance) | | | Australia | External review after objection | Must generally lodge objection first; then external review options (ART/Federal Court) | | | Germany (civil law) | Administrative act (tax assessment notice) | Objection (Einspruch) generally within one month | |

Cross-border enforcement instruments: what they allow (concept map)

These examples are formatted for direct classroom use. They are deliberately simplified to focus on structure; replace rates and statutory thresholds with your jurisdiction’s actual values.

Worked example: audit-driven debt with interest (U.K.-style simple interest illustration)

Scenario: HMRC compliance check finds a careless under‑assessment of Income Tax of £20,000 for a past year. The tax was due 12 months ago. The taxpayer makes an unprompted disclosure during the check and cooperates fully. Assume late payment interest is computed as simple interest from due date until paid; interest rate is base rate + 4% (use 7.75% as a worked numeric assumption for the year). HMRC late payment interest applies from due date until received.

Step A — Interest (simple): Interest = Tax × Rate × Time = 20,000 × 0.0775 × 1 = £1,550

Step B — Penalty range anchor (careless): For careless inaccuracies, the maximum is 30%. With unprompted disclosure, the minimum is 0% (can be reduced to nil depending on disclosure quality).

Total debt (simplified): £20,000 + £1,550 + £1,000 = £22,550

Teaching notes: Emphasize that (i) penalty is behavior + disclosure-quality dependent, and (ii) interest is time-value driven and mechanically continues until payment/arrangements.

Worked example: prompted vs unprompted penalty ranges (U.K. Schedule 24 teaching pattern)

Scenario: Additional tax assessed = £50,000. Behavior is “deliberate but not concealed.” Compare penalty ranges unprompted vs prompted under HMRC’s penalty tables.

From HMRC tables: Unprompted: max 70%, min 20%. Prompted: max 70%, min 35% (minimum increases because prompted disclosures can only reduce by up to half the max).

Compute penalty bounds: Unprompted penalty range: £50,000 × [20% … 70%] = £10,000 … £35,000 Prompted penalty range: £50,000 × [35% … 70%] = £17,500 … £35,000

Discussion pivot: why the “same behavior” yields a higher minimum when disclosure is prompted, and how “timing” and “access/helping/telling” quality factors affect where you fall within the range (tie to disclosure quality concepts embedded in the underlying law).

Worked example: Australia interest compounding sensitivity

Scenario: Primary tax debt AU$100,000 remains unpaid for 180 days. GIC is “worked out daily on a compounding basis.” Use a hypothetical annualized GIC rate of 10% to illustrate compounding effect (students plug in real rates from ATO’s GIC rates schedule in practice).

Approximation method for teaching: Daily rate r ≈ 0.10/365. Balance after 180 days ≈ 100,000 × (1 + r)^(180). Using r ≈ 0.00027397: (1+r)^(180) ≈ 1.050 (approx). Interest ≈ AU$5,000 (approximation for intuition; do not present as exact).

Teaching note: Even if interest rates look similar across countries, daily compounding (ATO) vs simple interest (many U.K. applications) changes the slope of debt growth.

Worked example: NGO/exempt entity — unrelated business income trigger (U.S. anchor)

Scenario: A tax-exempt organization runs a side business unrelated to its exempt purpose and earns $25,000 gross income and $8,000 directly connected expenses (simplified). Determine filing trigger and compute taxable base.

IRS rule anchor: if the exempt organization has $1,000 or more of gross income from an unrelated business, it must file Form 990‑T.

Taxable base (simplified): UBTI ≈ 25,000 − 8,000 = $17,000 Tax rate depends on entity classification and current corporate/trust rates (not computed here; substitute local/period applicable rates).

Compliance “debt risk” extension: if the NGO also fails to file annual information returns for three consecutive years, it risks automatic revocation of exemption.

Student problem set (with short solutions)

Problem 1 (Canada VDP interest relief): A taxpayer submits an unprompted VDP application for six prior years; estimated interest otherwise payable is CAD 12,000, and penalties would be CAD 7,000. Under IC00‑1R7 typical general relief, compute remaining interest and penalties (ignore discretionary variation).

Solution: General relief typical: 75% interest relief and 100% penalty relief → interest payable = 25% × 12,000 = CAD 3,000; penalties payable = CAD 0.

Problem 2 (Convention recovery eligibility intuition): Country A asks Country B to recover a tax claim against a nonresident taxpayer. What two conditions in the Convention should students check first?

Solution (conceptual): (i) Is there an enforceable instrument in applicant state; (ii) is the claim uncontested / no longer contestable (especially relevant where the claim is against a person not resident in the applicant state).

Problem 3 (Germany objection deadline): A German tax assessment notice is “made known” on March 1. By what date must an Einspruch be filed under AO §355 (simplify: ignore deemed service rules and weekends)?

Solution: Within one month → by April 1.

In-class activity sequence (180 minutes total): Start with a 10-minute diagnostic poll: “What makes a debt ‘special’?” Then run a 25-minute micro‑lecture on debt components/status, followed by three 30‑minute “situation labs” (audits; voluntary disclosure; cross‑border/government/NGO), each ending with a 5‑minute share‑out. Use the remaining time for two role-plays and a short quiz.

Activity lab prompts (small groups): Group outputs should be one page: (i) issue list, (ii) procedural map, (iii) numeric debt build, (iv) mitigation plan.

Audit lab: Use IRS examination process overview for mapping stages and where taxpayer response/appeal fits.

Disclosure lab: Use HMRC DDS 90‑day rule and Canada VDP relief tiers; groups decide which program(s) fit and what “completeness” means.

Cross‑border lab: Use Convention Articles 4 and 11 to decide whether EOI vs recovery request is viable and what “foreseeably relevant” means.

Role-play scenarios (scriptable)

Role-play A: Payment plan negotiation (taxpayer/representative vs tax authority officer) Roles: taxpayer CFO, tax adviser, tax authority collections officer. Objective: reach a payment arrangement while staying compliant.

Anchors for realism: - IRS: Form 9465 is used to request an installment agreement. - HMRC: government guidance describes “pay in instalments” if you cannot pay on time. - CRA: official page describes arranging to pay debt over time via payment arrangements. - ATO: payment plans guidance emphasizes plans can default if ongoing obligations aren’t met.

Performance rubric (3 criteria, 5 points each): (i) feasibility of installment offer; (ii) completeness of financial disclosure; (iii) compliance controls (future lodgments, segregation of funds, cadence).

Role-play B: Cross-border recovery and service (Competent Authority request) Roles: applicant state competent authority, requested state liaison, taxpayer counsel. Objective: draft a legally adequate request and anticipate objections.

Hook facts: taxpayer moved abroad; applicant state has final enforceable assessment; wants both bank info and recovery action. Use Convention requirements:

Discussion questions (Socratic-ready)

1) When is it ethically and strategically appropriate to recommend voluntary disclosure rather than wait for audit? Use the “prompted vs unprompted” framework. 2) Should interest be viewed as compensatory, punitive, or both? Compare HMRC interest setting (base rate linkage) with ATO daily compounding. 3) In cross-border recovery, what taxpayer‑rights risks arise from information exchange, and how do treaty frameworks acknowledge confidentiality and due process concerns? 4) Should government institutions be “outside VAT” for public authority functions? How does Article 13 framing create boundary disputes? 5) For an NGO, which is riskier: unrelated business income exposure or revocation/registration loss? Explain with the filing and revocation anchors.

Assessment items

Multiple choice questions (MCQs) (Provide students a separate answer sheet; below includes the key.)

1) Under HMRC’s penalty framework for inaccuracies, an “unprompted” disclosure generally allows which minimum for a careless inaccuracy? A. 15% B. 0% C. 20% D. 35% Answer: B.

2) Under HMRC DDS guidance, disclosure must generally be made within what period after HMRC acknowledges notification? A. 30 days B. 60 days C. 90 days D. 12 months Answer: C.

3) Under Canada’s IC00‑1R7, which statement best reflects typical relief for unprompted applications? A. 25% interest relief + 50% penalties relief B. 75% interest relief + 100% penalties relief C. 100% interest relief + 25% penalties relief D. No relief permitted if tax is owing Answer: B.

4) Under the OECD/Council of Europe Convention, information exchanged must be: A. public and unrestricted B. “foreseeably relevant” to specified tax purposes C. limited only to criminal tax cases D. supplied only if the taxpayer consents Answer: B.

5) Under the Convention, the requested state recovers tax claims of the applicant state: A. only by diplomatic negotiation B. only if the taxpayer is a resident of the requested state C. as if they were its own tax claims (subject to conditions) D. only if the claim is less than a monetary cap Answer: C.

6) In Australia, GIC on unpaid tax liabilities is calculated: A. monthly, simple interest B. daily on a compounding basis C. annually, fixed rate D. only after a court judgment Answer: B.

7) In the U.S., an exempt organization with at least how much gross income from an unrelated business must file Form 990‑T? A. $0 B. $500 C. $1,000 D. $10,000 Answer: C.

8) Which event can trigger automatic revocation of U.S. tax‑exempt status (as an IRS-administered rule)? A. One late filing of Form 990 B. Three consecutive years of failing to file required Form 990-series returns/notices C. Any year with a deficit D. Any unrelated business income Answer: B.

Short answer prompts (5–7 minutes each) 1) Explain why audit debt and disclosure debt differ in penalty posture even when tax principal is identical. Anchor your answer in “prompted vs unprompted” and “quality of disclosure.” 2) List four data elements that an applicant state should include in an international assistance request under the Convention framework (focus on identification, claim components, and requested action type). 3) Describe two ways a government entity can become a “tax debtor” even if it is exempt from some taxes. Provide one payroll/withholding example and one VAT/GST example. 4) In Canada’s VDP, why is payment (or payment arrangement request) part of eligibility screening? Explain from a collections-risk perspective. citeturn22view0 (rubric references eligibility and payment requirement) 5) Give one compliance control that prevents NGO revocation risk and one that prevents unrelated business income tax risk.

Compliance risks and mitigation (organized by the five special situations)

Audits: risk of compounding exposure from incomplete records, inconsistent explanations, and missed appeal windows; mitigate via audit-ready documentation, a single “source of truth” file, and early issue triage using the authority’s published process guidance.

Voluntary disclosures: risk of ineligibility (because the authority already has information), incomplete years, or inability to fund payment; mitigate through pre‑screening and program selection (e.g., HMRC DDS vs WDF vs VAT error correction; CRA VDP eligibility conditions; IRS CI VDP ineligibility triggers).

Cross‑border taxpayers: risk of “surprise discovery” due to exchange of information and delayed, multi‑jurisdiction recovery; mitigate by mapping treaties/conventions available, preserving evidence for residency/PE/withholding, and considering MAP where double taxation is possible.

Government institutions: risk concentrates in payroll withholding (volume + process failures) and VAT/GST boundary classification; mitigate via public‑sector tax control frameworks, function-by-function VAT/GST matrix (public authority vs commercial), and periodic internal compliance self‑assessment.

NGOs/exempt entities: revocation and UBI/UBIT risks are often “governance failures”; mitigate with calendarized filings, board oversight of compliance, and activity reviews for “unrelated business” flags.

Mermaid flows for teaching (timelines/decision charts)

Templates/forms with sample wording (adaptable)

These are teaching templates (not jurisdiction-specific legal advice). Pair each with the relevant official form/process in your jurisdiction.

Template: Voluntary disclosure cover letter (general)

[Date] To: [Tax Authority / Program Unit] Re: Voluntary disclosure – [Taxpayer name, TIN, address] Disclosure type: [Unprompted / Prompted] (where applicable) Tax types: [Income tax / VAT-GST / PAYE-withholding / Excise / Other] Years/periods: [YYYY–YYYY] 1. Purpose We are making a voluntary disclosure to correct [errors/omissions] in prior filings and to report previously unreported [income/gains/transactions]. 2. Summary of issues - Issue A: [describe] - Issue B: [describe] (Include cross-border facts if relevant: jurisdictions, accounts, entities, residency, withholding.) 3. Computation summary Attached schedules show: - Additional tax principal by year/period - Interest computation method and assumptions - Penalty position and disclosure-quality factors (telling/helping/giving access, where applicable) 4. Supporting documentation We attach [returns/forms/schedules/bank statements/contracts/invoices] for the relevant years. 5. Payment proposal We enclose payment of [amount] OR request a payment arrangement: Proposed plan: [amount per month], starting [date], ending [date]. Basis: [cash flow statement attached]. 6. Declaration We confirm this submission is complete and accurate to the best of our knowledge and includes all known errors/omissions within scope. Sincerely, [Name, title] [Authorized representative details]

Jurisdictional instructor note: - For HMRC DDS, emphasize “notify” and the 90‑day disclosure/payment deadline dynamics. - For CRA VDP, emphasize eligibility conditions and relief tiers; applications use Form RC199. - For ATO, emphasize “approved form” requirement and that GIC can continue accruing if unpaid.

Template: Payment plan request (collections unit)

[Date] To: [Collections Office] Subject: Request for payment arrangement – [Taxpayer name, reference number] We acknowledge the outstanding balance of [amount] for [tax type] covering [periods]. We request approval for a payment arrangement because we cannot pay in full by the due date. 1) Proposed installment schedule: - Initial payment: [amount] on [date] - Monthly payments: [amount] on the [day] of each month - Final payment: [amount] on [date] 2) Current compliance: We confirm all required returns are filed up to date and we will file and pay future obligations on time. 3) Financial disclosure: Attached: cash flow summary, bank statements, major creditors, and an asset/liability summary. 4) Hardship/risk context (if applicable): [Explain operational constraints, public-sector funding cycle, donor restrictions, etc.] Please confirm whether interest will continue to accrue on unpaid balances during the arrangement and any default conditions. Signed, [Name, title]

(Use official pathways where possible: IRS installment agreement request framework via Form 9465; HMRC “pay in instalments”; CRA payment arrangements; ATO payment plans.)

Template: Intergovernmental information exchange / recovery request (Competent Authority) This aligns to the Convention’s structure: specify the person, purpose, and requested action; for recovery, include claim components and assets; for service, include document nature.

[Date] From: Competent Authority, [Applicant State] To: Competent Authority Liaison, [Requested State] Re: Request for assistance under [Instrument: OECD/Council of Europe Convention / applicable treaty] 1) Type of request (tick all): [ ] Exchange of information on request [ ] Assistance in recovery of tax claims [ ] Measures of conservancy [ ] Service of documents 2) Taxpayer identification Name: [ ] Address(es): [ ] TIN/Tax reference: [ ] DOB/Entity registration: [ ] Related entities (if any): [ ] 3) Tax matters at issue Tax type(s): [ ] Periods/years: [ ] Legal basis in applicant state: [ ] Purpose: [assessment/collection/recovery/enforcement/prosecution consistent with instrument] 4) Information sought (if EOI) Describe information and relevance (foreseeably relevant standard): - [Bank account details / beneficial ownership / invoice chain / payroll records] Timeframe: [ ] Preferred format: [ ] 5) Recovery details (if recovery) Total claim amount: [principal + interest + penalties + costs] Enforceable instrument attached: [yes/no; attach certified copy] Contest status: [not contested / no longer contestable] (especially if debtor nonresident) 6) Known assets/actions requested Assets in requested state: [ ] Requested actions: [garnishment/levy/service of notice/etc.] 7) Confidentiality and use limitations Confirm use limited to permitted tax purposes under the instrument. Signed, [Name] [Title, Competent Authority]