And for the sake of brevity, I'll call one country Country 1 and the other country Country 2.

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The transmitting State may not require those foreign persons to obtain a TIN or provide a TIN to such payors of income in the transmitting State.

Decision of the Comptroller General of the United States, File No. B 288653, 31 October 2001, available at http archive.gao.gov legald425p10 a02467.pdf.

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The Committee recommends that the State party refer to its general comment No. 5.

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Where the domestic failings are attributable to a lack of training or a lack of resources, there would seem to be no reason why the State should refuse to submit a copy of the file.

Therefore, the transmitting State would have to transmit to the receiving State the relevant information codified by the TIN used in the receiving State.

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