Common use of Exchange of Information Upon Request Clause in Contracts

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request of the applicant Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an the applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, including, , (i) within the constraints of Article 2, ownership information on all such persons in an ownership chain; ; (ii) in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall formulate the request with the greatest detail possible and shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) the taxable period for which the information is sought; c) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (cd) the tax purpose for matter with respect to which the information is sought; (de) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement;; and (gh) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means within its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authorities, for the purposes specified in Article 1 and in accordance with Article 2 of the this Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, including ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant requesting Party shall provide provide, in writing, the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) the period of time for which the information is requested; c) a statement of the information sought including its nature and the form in which the applicant requesting Party wishes to receive the information from the requested Party; (cd) the tax purpose for which the information is sought; (de) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gh) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; b) If if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged provided without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means in its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use at its own discretion all relevant applicable information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not not, at that time, need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for authorities, in accordance with the purposes specified in Article 1 terms of the Agreement, this Agreement have the authority to obtain and provide upon request: a) information Information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity; and b) information Information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment funds and schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chainshares, units and other interests; in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, provided that this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the The identity of the person under examination or investigation;, (b) a statement The period for which the information is requested, c) The nature of the information sought including its nature and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Party;it, (cd) the The tax purpose for which the information is sought;, (de) grounds The reasons for believing that the information requested is foreseeably relevant to the tax administration and enforcement of the tax law of the requesting Party, with respect to the person identified in subparagraph a) of this paragraph, f) Grounds for believing that the information requested is held in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party;, (eg) to To the extent known, the name and address of any person believed to be in possession of the requested information;, (fh) a A statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement;, (gi) a A statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast reasonable delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant a requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, and beneficiaries; and in the case of foundations, information on founders, members of the foundation council council, and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant requesting Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person or persons under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant requesting Party wishes to receive the information from the requested Party; (c) the taxable periods for which the information is requested; d) the tax purpose for which the information is sought; (de) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gh) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, requesting Party explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement;of (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “"Anstalten” " and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. (1. ) The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. (2. ) If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. (3. ) If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. (4. ) Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. (5. ) The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. (6. ) The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, . (7) It is understood that the competent authority exchange of information provided in this Agreement does not include measures which constitute “fishing expeditions”. (8) It is understood that for the requested Party shall: a) Confirm receipt interpretation of a request in writing to this Agreement the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies principles established in the request, if any, within 60 days of the receipt of the requestOECD Commentaries shall be considered as well. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the a requested Party party shall provide upon request in writing information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party party if such conduct it occurred in the territory of the requested Partyparty. If the information received by the competent authority of the requested party is not sufficient to enable it to comply with the request for information, it shall advise the competent authority of the requesting party of that fact and request such additional information as may be required to enable the effective processing of the request. 2. If the information in the possession of the competent authority of the requested Party party is not sufficient to enable it to comply with the request for the information, that Party the requested party shall use all relevant information gathering measures to provide the applicant Party requesting party with the information requested, notwithstanding that the requested Party party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Partythe requesting party, the competent authority of the requested Party party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members members, beneficiaries and directors or other senior officers of the foundation council and beneficiariesfoundation. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties parties to obtain or provide provide: (a) ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties; (b) information relating to a period more than six years prior to the tax period under consideration; (c) information in the possession or control of a person other than the taxpayer that does not relate to the taxpayer. 56. The competent authority of the applicant Party requesting party shall provide the following information to the competent authority of the requested Party party when making a request for information under the this Agreement in order to demonstrate the foreseeable forseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature and type of the information sought requested, including its nature a description of the information and/or specific evidence sought, and the form in which the applicant Party wishes requesting party would prefer to receive the information from the requested Partyinformation; (cd) the tax purpose purposes for which the information is sought; (de) reasonable grounds for believing that the information requested is held present in the territory of the requested Party party or is in the possession or control of a person within subject to the jurisdiction of the requested Partyparty; (ef) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fg) a statement that the request is in conformity with this Agreement and the law laws and administrative practices of the applicant Partyrequesting party, and that if the requested information was were within the jurisdiction of the applicant Party requesting party then the competent authority of the applicant Party requesting party would be able to obtain the information under the laws of the applicant Party requesting party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; (gh) a statement that the applicant Party requesting party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The competent authority of the requested Party party shall forward the requested information as promptly as possible to the applicant Partycompetent authority of the requesting party. To ensure a prompt response, the competent authority of the requested Party party shall: (a) Confirm confirm the receipt of a request in writing to the competent authority of the applicant Party requesting party and shall notify the competent authority of the applicant Party requesting party of any deficiencies in the request, if any, request within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Party party has been unable to obtain and provide the information requested within 90 days of receipt of the request, including if it encounters obstacles are encountered in furnishing the information information, or it if the competent authority of the requested party refuses to furnish provide the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature competent authority of the obstacles or requesting party to explain the reasons for its inability or the obstacles or its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic internal laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement1, have the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The requested Party shall disclose any information that precedes the date on which this Agreement has effect for the taxes covered by the Agreement, insofar the information is foreseeably relevant for a taxable period or taxable event following that date. 6. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) the tax period for which information is requested; (c) the tax purpose for which the information is sought and the tax type(s) concerned; (d) a statement of the information sought sought, including its nature nature, its relevance to the purpose of the request, and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (de) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gh) a statement that the applicant Party has pursued all means available in within its own territory jurisdiction to obtain the information, except those that would give rise to disproportionate difficulties. 67. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; b) If if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. (1. ) The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means in its own territory, except where recourse to such means would give rise to disproportionate difficulty. (2. ) If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. (3. ) If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. (4. ) Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in authority, subject to the terms of Article 1 and within the constraints of the AgreementArticle 2, have the authority to obtain and provide provide, through its competent authority and upon request: a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership including information on all such persons in an ownership chain; ; (ii) in the case of trusts, information on settlors, trustees and beneficiaries; and ; (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this . (5) This Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a (6) Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is required; c) the nature of the information sought including its nature and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; e) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (da) of this paragraph; f) the grounds for believing that the information requested is held in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. (7) The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; b) If if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal. (8) It is understood that the exchange of information provided in this Agreement does not include measures aimed only at the random collection of pieces of evidence in order to commence an examination or investigation (“fishing expeditions”).

Exchange of Information Upon Request. (1. ) The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. (2. ) If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. (3. ) If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. (4. ) Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information Information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. (5. ) The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the The identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. (6. ) The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, . (7) It is understood that the competent authority exchange of information provided in this Agreement does not include measures which constitute “fishing expeditions”. (8) It is understood that for the requested Party shall: a) Confirm receipt interpretation of a request in writing to this Agreement the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies principles established in the request, if any, within 60 days of the receipt of the requestOECD Commentaries shall be considered as well. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain and the position in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant appropriate information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in Article authority, subject to the terms of Articles 1 and 2 of the this Agreement, have the authority to obtain and provide provide, through its competent authority and upon request: a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) information regarding the ownership of companies, partnerships, collective investment schemes, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership including information on all such persons in an ownership chain; , and (i) in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and ; (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries; and (iv) in the case of persons that are not collective investment schemes, trusts or foundations, equivalent information to the information in subparagraphs (i) to (iii). Further, Provided that this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; e) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to a person identified in subparagraph (da) of this paragraph; f) grounds for believing that the information requested is held present in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested information; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party requesting Party, shall advise if there are any unexpected delays in obtaining the requested information and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast reasonable delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain and the position in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. 7. To ensure a prompt response, It is understood that the competent authority exchange of information provided in this Agreement does not include measures which constitute “fishing expeditions”. 8. It is understood that for the requested Party shall: a) Confirm receipt interpretation of a request in writing to this Agreement the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies principles established in the request, if any, within 60 days of the receipt of the requestOECD Commentaries shall be considered as well. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the taxable period with respect to which the information is requested; d) the tax purpose for which the information is sought; (de) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gh) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Partyparty. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Applicant Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement;; and (g) a statement that the applicant Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant the information gathering measures it considers relevant to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in authority, subject to the terms of Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, includingincluding in the case of collective investment schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; shares, units and other interests; (c) in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. Further, this This Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 56. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible in specifying in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; (de) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is held present in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficultiesdifficulty. 67. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast possible delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 12. Such information shall be exchanged provided without regard to whether the conduct being investigated that is the subject of the request would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that the Requested Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the Agreement2, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees;; and (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 23, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this This Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information in writing to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information sought to the request: (a) the identity of the person under examination or investigationtaxpayer that is the subject of the request; (b) the identity of the person in respect of whom information is requested, if that person is not the taxpayer referred to in subparagraph (a); (c) a statement of the information sought requested including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (cd) the period of time with respect to which the information requested is required for the tax purposes; (e) the tax purpose purposes (including the legal grounds) for which the information requested is sought; (df) the reason for believing that the information requested is foreseeably relevant for the carrying out of this Agreement or to the administration or enforcement of the laws of the Applicant Party concerning taxes referred to in Article 4; (g) grounds for believing that the information requested is held in by the requested Requested Party or is in the possession or control of a person who is within the territorial jurisdiction of the requested Requested Party; (eh) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fi) a statement that the request is in conformity with the law laws and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice practices of the Applicant Party in similar circumstances and that it the request is in conformity with this the Agreement;; and (gj) a statement that the applicant Applicant Party has pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the information requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 sixty days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 ninety days of the receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant competent authority of the Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the applicant Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party party if such conduct it had occurred in the territory of the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an the applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten”, “Stiftungen” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, and equivalent information in the case of entities that are neither trusts nor foundations. FurtherNotwithstanding the preceding sentence, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestParty: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, : a) the competent authority of the requested Party shall: a) Confirm shall confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; b) If if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) a. information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) b. information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) a. the identity of the person under examination or investigation; (b) b. the period of time with respect to which information is requested; c. a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) d. the tax purpose for which the information is sought; (d) e. grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) f. to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) g. a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. 7. To ensure a prompt responseIt is understood that the exchange of information provided in this Agreement does not include measures which constitute “fishing expeditions”. 8. It is understood that for the interpretation of this Agreement the principles established in the OECD Commentaries, in the competent authority version existing at the day of entry into force of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and Agreement, shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the requestbe considered as well. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request in writing by the Requesting Party, information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the Requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct it occurred in the territory of the Requested Party. The competent authority of the Requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested Partyinformation by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that the Requested Party shall use all relevant information gathering measures to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, persons including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, and equivalent information in the case of entities that are neither trusts nor foundations. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: (a) ownership information with respect to publicly public traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 56. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its the nature and type of information requested, and the form in which the applicant Requesting Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested territory of the Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with this Agreement and the law and administrative practices of the applicant Requesting Party, that if the requested information was within the jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement;practice; and (g) a statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant competent authority of the Requesting Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: a) Confirm shall confirm the receipt of a request in writing to the competent authority of the applicant Requesting Party and shall notify the competent authority of the applicant Requesting Party of any deficiencies in the request, if any, request within 60 days of the receipt of the request. b) 8. If the competent authority of the requested Requested Party has been unable to obtain and provide the information requested within 90 days of receipt of the request, including or if it encounters obstacles are encountered in furnishing the information information, or it if the competent authority of the Requested Party refuses to furnish provide the information, it shall immediately inform the applicant Partycompetent authority of the Requesting Party in writing, explaining the reason reasons for its inabilityinability to obtain and provide the information, the nature of or the obstacles encountered or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party where it is satisfied there is cause for enquiry shall ensure that its competent authorities authority for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested PartyRequested Party and is foreseeably relevant to the tax purpose of the request; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Applicant Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement;; and (g) a statement that the applicant Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 12. Such information shall be exchanged provided without regard to whether the Requested Party needs such information for its own tax purposes or the conduct being investigated under examination would constitute a crime under the laws of the requested Requested Party if such conduct occurred in within the requested territorial jurisdiction of the Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that the Requested Party shall use all relevant information gathering measures necessary to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities it has the authority, for the purposes specified in Article 1 2 and within the constraints of the AgreementArticle 3, have the authority to obtain and provide provide, through its competent authority, upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity; and b(i) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, including, within the constraints of Article 2, including ownership information on all such persons in an ownership chain; ; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and and (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this This Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Requesting Party shall formulate a request for information under this Agreement with the greatest detail possible and shall provide the following information in writing to the competent authority of the requested Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information sought to the requestrequest for the purposes referred to in Article 2: (a) the identity of the person under examination or investigationexamination; (b) a statement the period of time with respect to which the information requested is required for the tax purposes of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Requesting Party; (c) the nature of the information requested and the form in which the Requesting Party prefers to receive the information from the Requested Party; (d) the tax purpose purposes for which the information requested is sought; (de) the reason why the information requested is foreseeably relevant to the request for the purposes referred to in Article 2; (f) grounds for believing that the information requested is held in by the requested Requested Party or is in the possession of or control of obtainable by a person who is within the territorial jurisdiction of the requested Requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant Requesting Party, that if the information requested information was within the territorial jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice practices of the Requesting Party and that it the request is in conformity with this the Agreement;; and (gi) a statement that the applicant Requesting Party has pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant a Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Requesting Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Requesting Party, that if the requested information was within the jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Requesting Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Requesting Party and shall notify the competent authority of the applicant Requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Requested Party has been unable to cannot obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such infor- mation for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the re- quested Party. The competent authority of the requesting Party shall only make a re- quest for information pursuant to this Article when it is unable to obtain the requested Partyinformation by other means in its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use at its own discretion all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not not, at that time, need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated au- thenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 and subject to Article 2 of the this Agreement, have has the authority to obtain and provide pro- vide upon request: a) information Information held by banks, other financial institutions, and any person person, in- cluding nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity; and b) information Information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment funds and schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chainshares, units and other interests; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide pro- vide ownership information with respect to publicly traded companies or public collective collec- tive investment funds or schemes unless such information can be obtained without giving giv- ing rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the The identity of the person under examination or investigation; (b) a statement The period for which the information is requested; c) The nature of the information sought including its nature and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the The tax purpose for which the information is sought; (de) grounds The reasons for believing that the information requested is foreseeably rele- vant to the tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph a) of this paragraph; f) Grounds for believing that the information requested is held in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction jurisdic- tion of the requested Party;, (eg) to To the extent known, the name and address of any person believed to be in possession of the requested information; (fh) a A statement that the request is in conformity with the law laws and administrative administra- tive practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice prac- xxxx and that it is in conformity with this Agreement; (gi) a A statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeav- ours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast reasona- ble delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) 1. information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) 2. information regarding the ownership of companies, partnerships, trusts, foundations, “«Anstalten” » and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) 1. the identity of the person under examination or investigation; (b) 2. a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) 3. the tax purpose for which the information is sought; (d) 4. grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) 5. to the extent known, the name and address of any person believed to be in possession of the requested information; (f) 6. a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) 7. a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) 1. Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) 2. If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant applicable information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in authority, subject to the terms of Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: a) information Information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity; and b) information Information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, including i) In the case of collective investment schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in shares, units and other interests; ii) In the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in and iii) In the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, ; provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the The identity of the person under examination or investigation; (b) a statement The period for which the information is requested; c) The nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the The tax purpose for which the information is sought; e) The reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (da) of this paragraph; f) The grounds for believing that the information requested is held present in the requested Party or is in the possession of, or control of obtainable by, a person within the jurisdiction of the requested Party; (eg) to To the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fh) a A statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a A statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast possible delay.

Exchange of Information Upon Request. 1. The competent authority of the a requested Party party shall provide upon request in writing by the requesting party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party party if such conduct it occurred in the territory of the requested Party. 2party. If the information in the possession of received by the competent authority of the requested Party party is not sufficient to enable it to comply with the request for information, it shall advise the competent authority of the requesting party of that Party fact and request such additional information as may be required to enable the effective processing of the request. 2. If the information in possession of the competent authority of the requested party is not sufficient to enable it to comply with the request for the information, the requested party shall use all relevant information gathering measures to provide the applicant Party requesting party with the information requested, notwithstanding that the requested Party party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Partythe requesting party, the competent authority of the requested Party party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party contracting party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” trusts and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; and in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries; and in protectors 5. Notwithstanding the case of foundations, information on founders, members of the foundation council and beneficiaries. Furtherpreceding paragraphs, this Agreement does not create an obligation on the Contracting Parties contracting parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 56. The competent authority of the applicant Party requesting party shall provide the following information to the competent authority of the requested Party party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature and type of the information requested, including a description of the specific evidence sought including its nature and the form in which the applicant Party wishes requesting party would prefer to receive the information from the requested Partyinformation; (cd) the tax purpose purposes for which the information is soughtsought and the reasons for believing that the information requested is foreseeably relevant to the administration or enforcement of the domestic laws of the requesting party; (de) reasonable grounds for believing that the information requested is held present in the territory of the requested Party party or is in the possession or control of a person within subject to the jurisdiction of the requested Partyparty; (ef) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fg) a statement that the request is in conformity with this Agreement and the law laws and administrative practices of the applicant Partyrequesting party, and that if the requested information was were within the jurisdiction of the applicant Party requesting party then the competent authority of the applicant Party requesting party would be able to obtain the information under the laws of the applicant Party requesting party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; (gh) a statement that the applicant Party requesting territory has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The competent authority of the requested Party party shall forward the requested information as promptly as possible to the applicant Partycompetent authority of the requesting party. To ensure a prompt response, the competent authority of the requested Party party shall: (a) Confirm confirm the receipt of a request in writing to the competent authority of the applicant Party requesting party and shall notify the competent authority of the applicant Party requesting party of any deficiencies in the request, if any, request within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Party party has been unable to obtain and provide the information requested within 90 days of receipt of the request, including if it encounters obstacles are encountered in furnishing the information information, or it if the competent authority of the requested party refuses to furnish provide the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature competent authority of the obstacles or requesting party to explain the reasons for its inability or the obstacles or its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that the Requested Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries; and the position in the case of foundations, information on founders, members of the foundation council and beneficiariesan ownership chain. Further, this This Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: (i) ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties; (ii) information that is not present in the Contracting Party; (iii) information relating to a period more than six years prior to the tax period under consideration. If information is requested relating to a person that is not a resident or national in one or other of the Contracting Parties, it also shall be established to the satisfaction of the competent authority of the Requested Party that such information is necessary for the proper administration and enforcement of the fiscal laws of the Applicant Party. Where such necessity had been duly established, the competent authorities shall consult as to the appropriate form of assistance. Where the Applicant Party requests information with respect to a matter which does not constitute serious tax evasion, a senior official of its competent authority shall certify that the request is relevant to, and necessary for, the determination of the tax liability of the taxpayer under the laws of the Applicant Party. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information sought to the request: (a) the identity of the person taxpayer under examination or investigationinvestigation and evidence that such taxpayer is a resident in, or national of, one of the Contracting Parties; (b) a statement the nature and type of the information sought requested, including its nature and a description of the form in which the applicant Party wishes to receive the specific evidence, information from the requested Partyor other assistance sought; (c) the tax purpose purposes for which the information is soughtsought and why it is relevant to, and necessary for, the determination of the tax liability of a taxpayer under the laws of the Applicant Party; (d) the period of time with respect to which the information is required for the tax purposes; (e) reasonable grounds for believing that the information requested is held present in the requested jurisdiction of the Requested Party or is in the possession or control of a person within subject to the jurisdiction of the requested PartyRequested Party and may be relevant to the tax purposes of the request; (ef) to the extent known, the name and address of any person believed to be in possession or control of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreementrequested; (g) a statement that the applicant request conforms to the law and administrative practice of the Applicant Party and would be obtainable by the Applicant Party under its laws in similar circumstances, both for its own tax purposes and in response to a valid request from the Requested Party under this Agreement; (h) a statement that the Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties; (i) where the request is directed at a person, other than the taxpayer, confirmation that only information in such person's possession or control that directly relates to the taxpayer need be provided. 6. The Notwithstanding the provisions of Article 10 in particular, the competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party party shall provide upon request by the requesting party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party party if such conduct it had occurred in the territory of the requested Partyparty. The competent authority of the requesting party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party party is not sufficient to enable it to comply with the request for information, that Party the requested party shall use all relevant appropriate information gathering measures necessary to provide the applicant Party requesting party with the information requested, notwithstanding that the requested Party party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Partythe requesting party, the competent authority of the requested Party party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in Article authority, subject to the terms of Articles 1 and 2 of the this Agreement, have the authority to obtain and provide provide, through its competent authority and upon request: a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) information regarding the ownership of companies, partnerships, collective investment schemes, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership including information on all such persons in an ownership chain; , and (i) in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and ; (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries; and (iv) in the case of persons that are neither collective investment schemes, trusts or foundations, equivalent information to the information in subparagraphs (i) to (iii). Further, Provided that this Agreement does not create an obligation on the Contracting Parties parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest possible detail possible and shall specify in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested c) the nature of the information sought including its nature requested and the form in which the applicant Party wishes requesting party would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; e) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting party, with respect to a person identified in subparagraph (da) of this paragraph; f) grounds for believing that the information requested is held present in the requested Party party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Partyparty; (eg) to the extent known, the name and address of any person believed to be in possession of of, or able to obtain the requested information; (fh) a statement that the request is in conformity with the law and administrative practices of the applicant Partyrequesting party, that if the requested information was within the jurisdiction of the applicant Party requesting party then the competent authority of the applicant Party requesting party would be able to obtain the information under the laws of the applicant Party requesting party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant Party requesting party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party requesting party, advise if there are any unexpected delays in obtaining the requested information and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested Party has been unable information to obtain and provide the information within 90 days of receipt of requesting party with the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast reasonable delay.

Exchange of Information Upon Request. 1. The competent authority of the requested a Requested Party shall provide upon request in writing by the Requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct it occurred in the requested territory of the Requested Party. 2. If the information in the possession of received by the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, it shall advise the competent authority of the Requesting Party of that fact, with suggestions of the additional information required to enable the effective processing of the request. 2. If the information in possession of the competent authority of the Requested Party is not sufficient to enable it to comply with the request for the information, the Requested Party shall use all relevant information gathering measures to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” trusts and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiariesprotectors. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the Agreement this Agreement, in order to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature and type of the information sought requested, including its nature a description of the specific evidence, information or other assistance sought, and the form in which the applicant Requesting Party wishes to receive the information from the requested Partyinformation; (cd) the tax purpose purposes for which the information is sought; (de) reasonable grounds for believing that the information requested is held present in the requested territory of the Requested Party or is in the possession or control of a person within subject to the jurisdiction of the requested PartyRequested Party and may be foreseeably relevant to the tax purpose of the request; (ef) to the extent known, the name and address of any person believed to be in possession or control of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreementrequested; (g) a declaration that the request conforms to the law and administrative practice of the Requesting Party and would be obtainable by the Requesting Party under its laws in similar circumstances, both for its own tax purposes and in response to a valid request from the Requested Party under this Agreement; (h) a statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant competent authority of the Requesting Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Party Requesting Party, and shall notify the competent authority of the applicant Requesting Party of any deficiencies in the request, if any, request within 60 days of the receipt of the request. (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information requested within 90 days of receipt of the request, including or if it encounters obstacles are encountered in furnishing the information information, or it if the competent authority of the Requested Party refuses to furnish provide the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature competent authority of the obstacles or Requesting Party and explain the reasons for its inability or the obstacles or its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information in writing to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the period of time with respect to which the information is requested; (d) the tax purpose for which the information is sought; (de) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gh) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Applicant Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement;; and (g) a statement that the applicant Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means within its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authorities, for the purposes specified in Article 1 and in accordance with Article 2 of the this Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, including ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant requesting Party shall provide provide, in writing, the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) the period of time for which the information is requested; c) a statement of the information sought including its nature and the form in which the applicant requesting Party wishes to receive the information from the requested Party; (cd) the tax purpose for which the information is sought; (de) grounds for believing that the information requested is held in the requested Party or is in the possession or control of or obtainable by a person within the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gh) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; b) If if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigationinvestigation and the period of time with respect to which the information is requested; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the territory of the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the this Agreement, have the authority to obtain and provide provide, upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, and equivalent information in the case of entities that are neither trusts nor foundations. FurtherNotwithstanding the preceding sentence, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information in writing to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person taxpayer under examination or investigation; (b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph a) of this paragraph; c) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (cd) the period of time with respect to which the information is requested; e) the tax purpose for which the information is sought including – i) the provision under the applicant Party’s tax or other law with respect to which the information is sought; (dii) whether the matter is a criminal tax matter; and iii) the reasons for believing that the information requested is foreseeably relevant to the applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph a) of this paragraph; f) the grounds for believing that the information requested is held present in the territory of the requested Party or is in the possession or control of a person within subject to the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of the requested information; (fh) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of its administrative practice and that it the request is in conformity with this Agreement;; and (gi) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 68. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party Party, shall advise if there are any unexpected delays in obtaining the requested information, and shall notify use its best endeavours to forward the competent authority of requested information to the applicant Party of deficiencies in with the request, if any, within 60 days of the receipt of the requestleast possible delay. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) a. information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) b. information regarding the ownership of companies, partnerships, trusts, foundations, “«Anstalten” » and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) a. the identity of the person under examination or investigation; (b) b. a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) c. the tax purpose for which the information is sought; (d) d. grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) e. to the extent known, the name and address of any person believed to be in possession of the requested information; (f) f. a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) g. a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) a. Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) b. If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. (1. ) The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. (2. ) If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. (3. ) If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. (4. ) Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. (5. ) The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. (6. ) The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, . (7) It is understood that the competent authority exchange of information provided in this Agreement does not include measures which constitute “fishing expeditions”. (8) It is understood that for the requested Party shall: a) Confirm receipt interpretation of a request in writing to this Agreement the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies principles established in the request, if any, within 60 days of the receipt of the requestOECD Commentaries shall be considered as well. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an the applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries, and beneficiariesthe position in an ownership chain; and in the case of foundations, information on founders, members of the foundation council and beneficiariesbeneficiaries and the position in an ownership chain. 5. Further, this This Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: (a) ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties; (b) information relating to a period more than six years prior to the tax period under consideration; (c) information unless the applicant Party has pursued all means available in its own Party to obtain the information, except those that would give rise to disproportionate difficulties; (d) information in the possession or control of a person other than the taxpayer that does not directly relate to the taxpayer. 56. Where the applicant Party requests information with respect to a matter which does not constitute serious tax evasion, a senior official of its competent authority shall certify that the request is relevant to, and necessary for, the determination of the tax liability of the taxpayer under the laws of the applicant Party. 7. If information is requested that relates to a person that is not a resident, nor a national, of one or other of the Parties, it also shall be established to the satisfaction of the competent authority of the requested Party that such information is necessary for the proper administration and enforcement of the fiscal laws of the applicant Party. 8. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information sought to the request: (a) the identity of the person taxpayer under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within subject to the jurisdiction of the requested Party; (ec) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fd) a statement that the request is in conformity with conforms to the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction practice of the applicant Party then the competent authority of and would be obtainable by the applicant Party would be able under its laws in similar circumstances, both for its own tax purposes and in response to obtain a valid request from the information requested Party under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (ge) a statement that the applicant Party has pursued all means available in its own territory Party to obtain the information, except those that would give rise to disproportionate difficulties; and, to the fullest extent possible: (f) the nature and type of the information requested, including a description of the specific evidence, information or other assistance sought and the form, in which the applicant Party prefers to receive the information; (g) the tax purposes for which the information is sought and why it is relevant to the determination of the tax liability of a taxpayer under the laws of the applicant Party; (h) information that such taxpayer is a resident in, or national of, one of the Parties, or that it is necessary for the determination of the tax liability of a taxpayer under the laws of the applicant Party; (i) the period of time with respect to which the information is required for the tax purposes. 69. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use at its own discretion all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in authority, subject to the terms of Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, Provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the request:greatest detail possible and shall specify in writing; (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; (de) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is held present in the requested Party or is in the possession of, or control of obtainable by, a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalas soon as possible.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigationinvestigation and the period of time with respect to which the information is requested; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Applicant Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement; (g) a statement that the applicant Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. (1. ) The competent authority of the requested Contracting Party shall provide upon request by the requesting Contracting Party information for the purposes referred to in Article 1. Such information shall be exchanged provided without regard to whether the requested Contracting Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Contracting Party if such conduct it had occurred in the territory of the requested Contracting Party. The competent authority of the requesting Contracting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means in its own territory, except where recourse to such means would give rise to disproportionate difficulty. (2. ) If the information in the possession of the competent authority of the requested Contracting Party is not sufficient to enable it to comply with the request for information, that Contracting Party shall use at its own discretion all relevant applicable information gathering measures necessary to provide the applicant requesting Contracting Party with the information requested, notwithstanding that the requested Contracting Party may not not, at that time, need such information for its own tax purposes. (3. ) If specifically requested by the competent authority of an applicant the requesting Contracting Party, the competent authority of the requested Contracting Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. (4. ) Each Contracting Party shall ensure that its competent authorities for authorities, in accordance with the purposes specified in Article 1 terms of the Agreement, this Agreement have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity, b(i) information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment funds and schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, provided that this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. (5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a ) Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the identity of the person under examination or investigation;, (b) a statement the period for which the information is requested, c) the nature of the information sought including its nature and the form in which the applicant requesting Contracting Party wishes would prefer to receive the information from the requested Party;it, (cd) the tax purpose for which the information is sought;, (de) the reasons for believing that the information requested is foreseeably relevant to the administration and enforcement of the tax law of the requesting Contracting Party, with respect to the person identified in subparagraph a) of this paragraph, f) grounds for believing that the information requested is held in the requested Contracting Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Contracting Party;, (eg) to the extent known, the name and address of any person believed to be in possession of the requested information;, (fh) a statement that the request is in conformity conforms with the law laws and administrative practices practice of the applicant Party, requesting Contracting Party and that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain obtainable by the information requesting Contracting Party under the its laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with response to a valid request made in similar circumstances from the requested Contracting Party under this Agreement;, (gi) a statement that the applicant requesting Contracting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. (6. ) The competent authority of the requested Contracting Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Contracting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Contracting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast reasonable delay.

Exchange of Information Upon Request. 1. (a) The competent authority of the requested Requested Party shall obtain and provide upon request in writing by the Requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon requestinclude: a(i) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees;; and b(ii) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. (b) The information referred to in subparagraph (a) shall be provided without regard to whether the conduct under examination would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. FurtherIf the information in the possession of the competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, the Requested Party shall use all relevant information gathering measures to provide the Requesting Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of the Requesting Party, the competent authority of the Requested Party shall provide information under this Article in the form of authenticated copies of original records. 4. This Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information sought to the request: (a) the identity of the person under examination or investigationthat is the subject of the request; (b) a statement the period of time with respect to which the information requested is required for the tax purposes of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Requesting Party; (c) the tax purpose for nature of the information requested and the form in which the information is soughtRequesting Party would prefer to receive the information; (d) the tax purposes for which the information requested is sought and the reason for believing that the information requested is foreseeably relevant to the administration or enforcement of the laws of the Requesting Party; (e) reasonable grounds for believing that the information requested is held in by the requested Requested Party or is in the possession or control of a person who is within the territorial jurisdiction of the requested Requested Party; (ef) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fg) a statement that that: (i) the request is in conformity with the law laws and administrative practices of the applicant Requesting Party, that ; (ii) if the information requested information was within the territorial jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it practices of the Requesting Party; and (iii) the request is in conformity with this the Agreement;; and (gh) a statement that the applicant Requesting Party has pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the information requested information as promptly as possible to the applicant competent authority of the Requesting Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Requesting Party and shall notify the competent authority of the applicant Requesting Party of deficiencies in the request, if any, within 60 sixty days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 ninety days of the receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant competent authority of the Requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information infor- mation for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under un- der the laws of the requested Requested Party if such conduct occurred in the Requested Party. The competent authority of the Requesting Party shall only make a request for infor- mation pursuant to this Article when it is unable to obtain the requested Partyinformation by other means in its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures necessary to provide the applicant Request- ing Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for authorities, in accordance with the purposes specified in Article 1 terms of the Agreement, this Agreement have the authority to obtain and provide upon request: a) information Information held by banks, other financial institutions, and any person person, in- cluding nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity; and b) information Information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment funds and schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chainshares, units and other interests; in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, provided that this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective col- lective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the The identity of the person under examination or investigation; (b) a statement The period for which the information is requested; c) The nature of the information sought including its nature and the form in which the applicant Requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the The tax purpose for which the information is sought; (de) grounds The reasons for believing that the information requested is foreseeably rele- vant to the tax administration and enforcement of the law of the Requesting Party, with respect to the person identified in subparagraph a) of this para- graph; f) Grounds for believing that the information requested is held in the requested Requested Party or is in the possession of or control of obtainable by a person within the jurisdiction jurisdic- tion of the requested Requested Party;, (eg) to To the extent known, the name and address of any person believed to be in possession of the requested information; (fh) a A statement that the request is in conformity with the law laws and administrative administra- tive practices of the applicant Requesting Party, that if the requested information was within the jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Requesting Party or in the normal course of administrative practice prac- xxxx and that it is in conformity with this Agreement; (gi) a A statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information in- formation as promptly as possible to the applicant Requesting Party. To ensure a prompt responsere- sponse, the competent authority of the requested Requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Re- questing Party and shall notify the competent authority of the applicant Requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including includ- ing if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons rea- sons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request in writing by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant appropriate information gathering measures to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Notwithstanding any contrary provisions in its domestic laws, each Party shall ensure that its competent authorities for have the purposes specified in Article authority, subject to the terms of Articles 1 and 2 of the this Agreement, have the authority to obtain and provide upon requestto provide: a) information held by banks, other financial institutions, trusts, foundations and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) information regarding the ownership of companies, partnerships, collective investment schemes, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership including information on all such persons in an ownership chain; , and (i) in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and ; (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries; and (iv) in the case of persons that are neither collective investment schemes, trusts or foundations, equivalent information to the information in subparagraphs (i) to (iii). Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority A Contracting Party may request information from the other Party even if that requesting Party would not be able to obtain such information for its own purposes under its laws or in the normal course of the applicant Party shall provide the following information to the competent authority of its administrative practice if the requested Party when making a information was within its jurisdiction. 6. Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest possible details and shall specify in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; e) the reasons for believing that the information requested is foreseeably relevant to the administration or enforcement of the taxes of the requesting Party covered under Article 3, with respect to a person identified in subparagraph (da) of this paragraph; f) grounds for believing that the information requested is held present in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of of, or able to obtain the requested information; (fh) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiesdifficulty. 67. The Notwithstanding the provisions of Article 10 in particular, the competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 11 (Object and Scope of this Agreement) upon request by the competent authority of the applicant Party. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. In the execution of a request by the requested Party, only those privileges under the laws and practices of the requested Party shall apply. 3. If specifically requested by the competent authority of an the applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic internal laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 (Object and Scope of the this Agreement) of this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees;; and (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 22 (Jurisdiction), ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. FurtherNotwithstanding subparagraph 4(b), this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficultiesdifficulties to the requested Party. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person or ascertainable group or category of persons under examination or investigation; (b) a statement of the information sought sought, including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the period of time with respect to which the information is requested; (d) the tax purpose for which the information is soughtsought including the tax type of the applicant Party; (de) grounds for believing that the information requested is foreseeably relevant to tax administration or enforcement of the applicant Party with respect to the person or group or category of persons identified in subparagraph 5(a); (f) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession or control of the requested information; (fh) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement;; and (gi) a statement that the applicant Party has pursued all means available in its own territory geographic area of jurisdiction to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use at its own discretion all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in authority, subject to the terms of Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, includingincluding in the case of collective investment schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, Provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; (de) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is held present in the requested Party or is in the possession of, or control of obtainable by, a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward acknowledge receipt of the requested information as promptly as possible to the applicant Party. To ensure a prompt response, request of the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalas soon as possible.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought, including a statement of the law imposing the tax to which the request relates; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. (a) The competent authority of the requested Requested Party shall obtain and provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon requestinclude: a(i) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees;; and b(ii) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. (b) The information referred to in subparagraph (a) shall be provided without regard to whether the Requested Party needs such information for its own tax purposes or whether the conduct under examination would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. FurtherIf the information in the possession of the competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, the Requested Party shall use all relevant information gathering measures to provide the Applicant Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of the Applicant Party, the competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its laws, in the form of authenticated copies of original records. 4. This Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information in writing to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information sought to the request: (a) the identity of the person under examination or investigationexamination; (b) with respect to taxes levied on the basis of a taxable year, the taxable year to which the request relates; (c) a statement of the information sought requested including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (cd) the tax purpose purposes for which the information requested is sought; (de) the reason for believing that the information requested is foreseeably relevant to the administration or enforcement of the laws of the Applicant Party with regard to the person specified in subparagraph (a); (f) grounds for believing that the information requested is held in by the requested Requested Party or is in the possession or control of a person who is within the territorial jurisdiction of the requested Requested Party; (eg) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices practice of the applicant Applicant Party, that if the information requested information was within the territorial jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice of the Applicant Party and that it the request is in conformity with this the Agreement;; and (gi) a statement that the applicant Applicant Party has pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the information requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 sixty days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 ninety days of the receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant competent authority of the Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “”Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Applicant Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement; (g) a statement that the applicant Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the this Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm shall confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) 7. If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request.  1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party.  2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes.  3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records.  4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: o a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; o b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties.  5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (o a) the identity of the person under examination or investigation; (o b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (o c) the tax purpose for which the information is sought; (o d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (o e) to the extent known, the name and address of any person believed to be in possession of the requested information; (o f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (o g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties.  6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: o a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. o b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the a requested Party shall provide upon request in writing information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime tax offence under the laws of the requested Party if such conduct it occurred in the territory of the requested Party. If the information received by the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, it shall advise the competent authority of the requesting Party of that fact and request such additional information as may be required to enable the effective processing of the request. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for the information, that the requested Party shall use all relevant information gathering measures to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, and beneficiaries; and in the case of foundations, information on founders, members members, beneficiaries and directors or other senior officers of the foundation council and beneficiariesfoundation. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 56. The competent authority of the applicant requesting Party shall provide the following information to the competent authority of the requested Party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; c) the nature and type of the information sought requested, including its nature a description of the information and/or specific evidence sought, and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyinformation; (cd) the tax purpose purposes for which the information is sought; (de) grounds for believing that the information requested is held present in the territory of the requested Party or is in the possession or control of a person within subject to the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fg) a statement that the request is in conformity with this Agreement and the law laws and administrative practices of the applicant requesting Party, and that if the requested information was were within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; (gh) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant competent authority of the requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant requesting Party of any deficiencies in the request, if any, request within 60 days of the receipt of the request.; and b) If immediately inform the competent authority of the requesting Party to explain the reasons for its inability or the obstacles or its refusal, if the competent authority of the requested Party has been unable to obtain and provide the information requested within 90 days of receipt of the request, including if it encounters obstacles are encountered in furnishing the information information, or it if the competent authority of the requested Party refuses to furnish provide the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the Agreement, have has the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “"Anstalten” " and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to provide or obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Applicant Party or in the normal course of administrative practice and that it the request is in conformity with this Agreement;; and (g) a statement that the applicant Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. If the information received by the competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, it shall advise the competent authority of the Requesting Party of that fact and request such additional information as may be required to enable the effective processing of the request. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” trusts and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiariesprotectors;. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. Notwithstanding the preceding paragraph, this Agreement does not create an obligation on the Contracting Parties to obtain or provide information which is older than a legally required time period for retaining that information in the jurisdiction of the Requested Party and where that information is in fact no longer kept. 6. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) a statement of the information sought including its nature and the form in which the applicant Requesting Party wishes to receive the information from the requested Requested Party; (cd) the tax purpose for which the information is sought; (de) reasonable grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within subject to the jurisdiction of the requested Requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant Requesting Party, that if the requested information was within the jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Requesting Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement;; and (gh) a statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Requesting Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Requesting Party and shall notify the competent authority of the applicant Requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request by the Requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged provided without regard to whether the Requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct it had occurred in the territory of the Requested Party. The competent authority of the Requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested Partyinformation by other means in its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for the information, that the Requested Party shall use all relevant information gathering measures to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for authorities, in accordance with the purposes specified in Article 1 terms of the Agreement, this Agreement have the authority to obtain and provide upon request: a) information Information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity; and b) information Information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment funds and schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chainshares, units and other interests; in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, provided that this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the The identity of the person under examination or investigation;, (b) a statement The period for which the information is requested, c) The nature of the information sought including its nature and the form in which the applicant Requesting Party wishes would prefer to receive the information from the requested Party;it, (cd) the The tax purpose for which the information is sought;, (de) grounds The reasons for believing that the information requested is foreseeably relevant to the tax administration and enforcement of the tax law of the Requesting Party, with respect to the person identified in subparagraph a) of this paragraph, f) Grounds for believing that the information requested is held in the requested Requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Requested Party;, (eg) to To the extent known, the name and address of any person believed to be in possession of the requested information;, (fh) a A statement that the request is in conformity with the law laws and administrative practices of the applicant Requesting Party, that if the requested information was within the jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement;, (gi) a A statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant a Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Requesting Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Requesting Party, that if the requested information was within the jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Requesting Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Requesting Party and shall notify the competent authority of the applicant Requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Requested Party has been unable to cannot obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the competent authority of the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities it has the authority, for the purposes specified in Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) information regarding the ownership of companies, partnerships, collective investment schemes, trusts, foundations, “"Anstalten” ", "Stiftungen" and other persons, including, : i) within the constraints of Article 2, ownership information on all such persons in an ownership chain; and ii) in the case of collective investment schemes, information on shares, units and other interests; and iii) in the case of trusts, information on settlors, trustees and beneficiaries; and and iv) in the case of foundations, information on founders, members of the foundation council and beneficiariesbeneficiaries and equivalent information in the case of entities that are neither trusts nor foundations. Further, Provided that this Agreement does not create an obligation on the Contracting Parties either Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under this Agreement shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible in specifying in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; e) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the domestic laws of the requesting Party, with respect to the person identified in (da) of this paragraph; f) grounds for believing that the information requested is held present in the requested Party or is in the possession or control power of a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession or power of the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party requesting Party, shall advise if there are any unexpected delays in obtaining the requested information, and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast possible delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “‘Anstalten” ’ and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Applicant Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement; (g) a statement that the applicant Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use use, at its own discretion, all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in authority, subject to the terms of Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, includingincluding in the case of collective investment schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and beneficiaries and, in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, ; provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; (de) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) the grounds for believing that the information requested is held present in the requested Party or is in the possession of, or control of obtainable by, a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast reasonable delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in territorial jurisdiction of the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 I of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “"Anstalten” " and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties., 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, : a) the competent authority of the requested Party shall: a) Confirm shall confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement;able (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant appropriate information gathering measures to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Notwithstanding any contrary provisions in its domestic laws, each Party shall ensure that its competent authorities for have the purposes specified in Article authority, subject to the terms of Articles 1 and 2 of the this Agreement, have the authority to obtain and provide upon requestto provide: a) information held by banks, other financial institutions, trusts, foundations and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) information regarding the ownership of companies, partnerships, collective investment schemes, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership including information on all such persons in an ownership chain; , and (i) in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and ; (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries; and (iv) in the case of persons that are neither collective investment schemes, trusts or foundations, equivalent information to the information in subparagraphs (i) to (iii). Further, Provided that this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest possible details and shall specify in writing: (a) the identity of the person taxpayer under examination or investigation; (b) a statement the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) the period for which the information is requested; d) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (ce) the tax purpose for which the information is sought, including: (i) the citation of the legal authority under the applicant Party’s tax law with respect to which the information is sought; and (ii) whether the matter is a criminal tax matter; f) the reasons for believing that the information requested is foreseeably relevant to the administration or enforcement of the taxes of the requesting Party covered under Article 3, with respect to a person identified in subparagraph (da) of this paragraph; g) grounds for believing that the information requested is held present in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eh) to the extent known, the name and address of any person believed to be in possession of of, or able to obtain the requested information; (fi) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gj) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party requesting Party, advise if there are any unexpected delays in obtaining the requested information and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast reasonable delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request in writing by the Requesting Party, information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct it occurred in the requested territory of the Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that the Requested Party shall use all relevant information gathering measures to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations,"Anstalten" and other persons, persons including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries; and in the case of entities that are neither trusts nor foundations, equivalent information as previously stated for trusts and foundations. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: (a) ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties; (b) information which exceeds the legally required time period for retaining that information in the jurisdiction of the Requested Party and where that information is in fact no longer kept; (c) information in the possession or control of a person other than the taxpayer that does not directly relate to the taxpayer. 56. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature and type of the information requested, including a description of the specific evidence sought including its nature and the form in which the applicant Requesting Party wishes to receive the information from the requested Partyinformation; (cd) the tax purpose purposes for which the information is soughtsought and the reasons why the information requested is foreseeably relevant to the administration or enforcement of the domestic laws of the Requesting Party; (de) grounds for believing that the information requested is held present in the requested territory of the Requested Party or is in the possession or control of a person within subject to the jurisdiction of the requested Requested Party; (ef) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fg) a statement that the request is in conformity with this Agreement and the law laws and administrative practices of the applicant Party, Requesting Party and that if the requested information was within the jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; (gh) a statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant competent authority of the Requesting Party. To ensure a prompt response, response the competent authority of the requested Requested Party shall: a) Confirm shall confirm the receipt of a request in writing to the competent authority of the applicant Requesting Party and shall notify the competent authority of the applicant Requesting Party of any deficiencies in the request, if any, request within 60 days of the receipt of the request. b) 8. If the competent authority of the requested Requested Party has been unable to obtain and provide the information requested within 90 days of receipt of the request, including or if it encounters obstacles are encountered in furnishing the information information, or it if the competent authority of the Requested Party refuses to furnish provide the information, it shall immediately inform the applicant Partycompetent authority of the Requesting Party in writing, explaining the reason reasons for its inabilityinability to obtain and provide the information, the nature of or the obstacles encountered or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (g) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: (a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. (b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 12. Such information shall be exchanged provided without regard to whether the conduct being investigated under examination would constitute a crime under the laws of the requested Requested Party if such conduct occurred in within the requested territorial jurisdiction of the Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that the Requested Party shall use all relevant information gathering measures necessary to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the Agreement2, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity; and (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, persons including, within the constraints of Article 23, ownership information on all such persons in an ownership chain; . Such information includes: (i) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and and (ii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. Further, this This Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 56. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information sought to the request: (a) the identity of the person under examination or investigationexamination; (b) a statement of the information sought requested including its nature and the form in which the applicant Requesting Party wishes to receive the information from the requested Requested Party; (c) the tax purpose purposes for which the information requested is sought; (d) grounds for believing that the information requested is held in by the requested Requested Party or is in the possession or control of a person who is within the territorial jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (f) a statement that the request is in conformity with the law laws and administrative practices of the applicant Requesting Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice practices of the Requesting Party in similar circumstances and that it the request is in conformity with this the Agreement;; and (g) a statement that the applicant Requesting Party has pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant applicable information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not not, at that time, need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in authority, subject to the terms of Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and beneficiaries and, in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, ; provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; (de) the reasons for believing that the information requested is foreseeable relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is held in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fh) a statement that the request is in conformity with the law and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalas soon as possible.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information infor- mation for the purposes referred to in Article 1. Such information shall be exchanged without with- out regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information infor- mation for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article Ar- ticle 1 of the Agreement, have the authority to obtain and provide upon request: a) information Information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees;; and b) information Information regarding the ownership of companies, partnerships, trusts, foundationsfounda- tions, “Anstalten” and other persons, including, within the constraints of Article 2, ownership owner- ship information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundationsfounda- tions, information on founders, members of the foundation council and beneficiariesbenefi- ciaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies compa- xxxx or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information infor- mation to the request: (a) the The identity of the person under examination or investigation; (b) a A statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (c) the The tax purpose for which the information is sought; (d) grounds Grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to To the extent known, the name and address of any person believed to be in possession of the requested information; (f) a A statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity conform- ity with this Agreement; (g) a A statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate dispro- portionate difficulties. 6. The competent authority of the requested Party shall forward the requested information infor- mation as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant appli- cant Party and shall notify the competent authority of the applicant Party of deficiencies de- ficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the informationin- formation, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an the applicant Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; c) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; (cd) the tax purpose for which the information is sought; (de) grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (ef) to the extent known, the name and address of any person believed to be in possession of the requested information; (fg) a statement that the request is in conformity with the law and administrative practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gh) a statement that the applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged provided without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means in its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use at its own discretion all relevant applicable information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not not, at that time, need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for authorities, in accordance with the purposes specified in Article 1 terms of the Agreement, this Agreement have the authority to obtain and provide upon request: a) information Information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trustees;capacity; and b) information Information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment funds and schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chainshares, units and other interests; in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, provided that this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the The identity of the person under examination or investigation; (b) a statement The period for which the information is requested; c) The nature of the information sought including its nature and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the The tax purpose for which the information is sought; (de) grounds The reasons for believing that the information requested is foreseeably relevant to the tax administration and enforcement of the tax law of the requesting Party, with respect to the person identified in subparagraph a) of this paragraph; f) Grounds for believing that the information requested is held in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eg) to To the extent known, the name and address of any person believed to be in possession of the requested information; (fh) a A statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a A statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To competent authority of the requesting Party and to ensure a prompt response, the competent authority of the requested Party shall: a) Confirm the receipt of a request in writing to the competent authority of the applicant Requesting Party and shall notify the competent authority of the applicant Requesting Party of any deficiencies in the request, if any, request within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.;

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall at its own discretion use all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities it has the authority, for the purposes specified referred to in Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, includingincluding in the case of collective investment schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the request:greatest detail possible in specifying in writing; (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; (de) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is held in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalas soon as possible.

Exchange of Information Upon Request. 1. The competent authority of the requested Party party shall provide upon request by the requesting party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party party if such conduct it had occurred in the territory of the requested Partyparty. The competent authority of the requesting party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party party is not sufficient to enable it to comply with the request for information, that Party the requested party shall use take all relevant information gathering measures to provide the applicant Party requesting party with the information requested, notwithstanding that the requested Party party may not not, at that time, need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Partythe requesting party, the competent authority of the requested Party party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party party shall ensure that its competent authorities it has the authority, for the purposes specified referred to in Article 1 of the this Agreement and subject to Article 2 of this Agreement, have the authority to obtain and provide provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment funds, within the constraints of Article 2, ownership information on all such persons in an ownership chainshares, units and other interests; and in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, provided that this Agreement does not create an obligation on the Contracting Parties for a party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes funds, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under made by a party shall be framed with the Agreement to demonstrate greatest degree of specificity possible. In all cases, such requests shall specify in writing the foreseeable relevance of the information to the requestfollowing: (a) the identity of the person taxpayer under examination or investigation; (b) a statement the period of time with respect to which the information is requested; (c) the nature of the information sought including its nature requested and the form in which the applicant Party wishes requesting party would prefer to receive the information from the requested Partyit; (cd) the matter under the requesting party’s tax purpose for law with respect to which the information is sought; (de) the reasons for believing that the information requested is foreseeably relevant or material to tax administration and enforcement of the requesting party, with respect to the person identified in subparagraph (a) of this paragraph; (f) reasonable grounds for believing that the information requested is held present in the requested Party party or is in the possession or control of a person within the jurisdiction of the requested Partyparty; (eg) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fh) a statement that the request is in conformity with conforms to the law and administrative practices practice of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party requesting party and would be able to obtain obtainable by the information requesting party under the its laws of the applicant Party or in the normal course of administrative practice in similar circumstances, both for its own tax purposes and that it is in conformity with response to a valid request from the requested party under this Agreement; (gi) a statement that the applicant Party requesting party has pursued all reasonable means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means within its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for it has the purposes specified in authority, subject to the terms of Article 1 and within the constraints of the AgreementArticle 2, have the authority to obtain and provide provide, through its competent authority, and upon request: a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees capacity. Provided that, in the case of Chile being the requested Party, if the information is covered by Article 1 of DFL N° 707 and trusteesArticle 154 of DFL N° 3 of Chile, it shall be available with respect to bank transactions occurring on or after January 1, 2010; b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; ; c) in the case of trusts, information on settlors, trustees trustees, protectors, enforcers and beneficiaries; and and d) in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 56. The competent authority of Any request for information shall be formulated with the applicant Party greatest detail possible and shall provide specify in writing the following information to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestrequested information: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; (de) the reasons for believing that the information requested is foreseeably relevant for the purposes referred to in Article 1; f) the grounds for believing that the information requested is held present in the requested Party or is in the possession of, or is in the control of or obtainable by, a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested information; (fh) a statement that the request is in conformity with the law and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficulties. 67. The competent authority of the requested Party shall use its best endeavours to forward the requested information as promptly as possible to the applicant Partyrequesting Party with the least possible delay. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request.; b) If if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant competent authority of the requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall formulate a request for information under this Agreement with sufficient detail and shall provide the following information in writing to the competent authority of the requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestRequested Party: (a) the identity of the person taxpayer under examination or investigation; (b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; (c) a statement of the information sought including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (cd) the period of time with respect to which the information is requested; (e) the tax purpose for which the information is sought, including: (i) the citation of the legal authority under the Applicant Party’s tax law with respect to which the information is sought; (dii) whether the matter is a criminal tax matter; and (iii) the reasons for believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; (f) the grounds for believing that the information requested is held in the requested Requested Party or is in the possession or control of a person within the jurisdiction of the requested Requested Party; (eg) to the extent known, the name and address of any person believed to be in possession of the requested information; (fh) a statement that the request is in conformity with the law and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Applicant Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement;; and (gi) a statement that the applicant Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant Party Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the Applicant Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast possible delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct occurred in the requested Party. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic internal laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) information regarding the ownership of companies, partnerships, trusts, foundations, “"Anstalten” " and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant requesting Party shall provide the following information to the competent authority of the requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement of the information sought including its nature and the form in which the applicant requesting Party wishes to receive the information from the requested Party; (c) the tax purpose for which the information is sought; (d) the grounds for believing that the information requested is held in the requested Party or is in the possession or control of a person within the jurisdiction of the requested Party; (e) to the extent known, the name and address of any person believed to be in possession of the requested information; (f) a statement that the request is in conformity with the law and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it the information request is in conformity with this Agreement;; and (g) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant requesting Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if such conduct it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use use, at its own discretion, all relevant information gathering measures necessary to provide the applicant requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities it has the authority, for the purposes specified referred to in Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) information regarding the beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, includingincluding in the case of collective investment schemes, within the constraints of Article 2, ownership information on all such persons in an ownership chain; shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Party shall provide the following information to the competent authority of the requested Party when making a Any request for information under shall be formulated with the Agreement to demonstrate the foreseeable relevance of the information to the requestgreatest detail possible and shall specify in writing: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature of the information sought including its nature requested and the form in which the applicant requesting Party wishes would prefer to receive the information from the requested Partyit; (cd) the tax purpose for which the information is sought; (de) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) the grounds for believing that the information requested is held present in the requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the requested Party; (eg) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fh) a statement that the request is in conformity with the law laws and administrative practices of the applicant requesting Party, that if the requested information was within the jurisdiction of the applicant requesting Party then the competent authority of the applicant requesting Party would be able to obtain the information under the laws of the applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; (gi) a statement that the applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficultiesdifficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the applicant Party. To ensure a prompt response, the competent authority acknowledge receipt of the requested Party shall: a) Confirm receipt of a request in writing to the competent authority of the applicant requesting Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of use its best endeavours to forward the requested information to the requesting Party has been unable to obtain and provide with the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusalleast possible delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request information for the purposes referred to in Article 12. Such information shall be exchanged provided without regard to whether the conduct being investigated under examination would constitute a crime under the laws of the requested Requested Party if such conduct occurred in the requested Requested Party. 2. If the information in the possession of the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, that the Requested Party shall use all relevant information gathering measures to provide the applicant Applicant Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Applicant Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority for the purposes specified in Article 1 of the Agreement2, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees;; and (b) information regarding the ownership of companies, partnerships, trusts, foundations, “Anstalten” foundations and other persons, including, within the constraints of Article 23, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this This Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The competent authority of the applicant Applicant Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information sought to the request: (a) the identity of the person under examination or investigationexamination; (b) a statement of the information sought requested including its nature and the form in which the applicant Applicant Party wishes to receive the information from the requested Requested Party; (c) the tax purpose purposes for which the information requested is sought; (d) grounds for believing that the information requested is held in by the requested Requested Party or is in the possession or control of a person who is within the territorial jurisdiction of the requested Requested Party; (e) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (f) a statement that the request is in conformity with the law laws and administrative practices of the applicant Applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Applicant Party would be able to obtain the information under the laws of the applicant Party or in the normal course of administrative practice practices of the Applicant Party in similar circumstances and that it the request is in conformity with this the Agreement;; and (g) a statement that the applicant Applicant Party has pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except those that would give rise to disproportionate difficulties. 6. The competent authority of the requested Requested Party shall forward the information requested information as promptly as possible to the applicant Applicant Party. To ensure a prompt response, the competent authority of the requested Requested Party shall: (a) Confirm confirm receipt of a request in writing to the competent authority of the applicant Applicant Party and shall notify the competent authority of the applicant Applicant Party of deficiencies in the request, if any, within 60 sixty days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information within 90 ninety days of the receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested a Requested Party shall provide upon request in writing by the Requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the requested Requested Party if such conduct it occurred in the requested territory of the Requested Party. 2. If the information in the possession of received by the competent authority of the requested Requested Party is not sufficient to enable it to comply with the request for information, it shall, in accordance with the terms provided in paragraph 7 (a), advise the competent authority of the Requesting Party of that fact and request such additional information as may be required to enable the effective processing of the request. 2. If the information in possession of the competent authority of the Requested Party is not sufficient to enable it to comply with the request for the information, the Requested Party shall use all relevant information gathering measures to provide the applicant Requesting Party with the information requested, notwithstanding that the requested Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the competent authority of an applicant the Requesting Party, the competent authority of the requested Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its competent authorities authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations, “Anstalten” partnerships and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; and in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, and equivalent information in the case of entities that are neither trusts nor foundations. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: (a) ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties; (b) information relating to a period more than six years prior to the tax period under consideration; (c) information in the possession or control of a person other than the taxpayer that does not directly relate to the taxpayer. 56. The competent authority of the applicant Requesting Party shall provide the following information to the competent authority of the requested Requested Party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the person under examination or investigation; (b) a statement the period for which the information is requested; (c) the nature and type of the information requested, including a description of the specific evidence sought including its nature and the form in which the applicant Requesting Party wishes would prefer to receive the information from the requested Partyinformation; (cd) the tax purpose purposes for which the information is soughtsought and the reasons why the information requested is foreseeably relevant to the administration or enforcement of the domestic laws of the Requesting Party; (de) grounds for believing that the information requested is held present in the requested territory of the Requested Party or is in the possession or control of a person within subject to the jurisdiction of the requested Requested Party; (ef) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; (fg) a statement declaration that the request is in conformity with this Agreement and the law laws and administrative practices of the applicant Requesting Party, and that if the requested information was were within the jurisdiction of the applicant Requesting Party then the competent authority of the applicant Requesting Party would be able to obtain the information under the laws of the applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; (gh) a statement that the applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The competent authority of the requested Requested Party shall forward the requested information as promptly as possible to the applicant competent authority of the Requesting Party. To ensure a prompt response, : (a) the competent authority of the requested Requested Party shall: a) Confirm shall confirm the receipt of a request in writing to the competent authority of the applicant Requesting Party and shall notify the competent authority of the applicant Requesting Party of any deficiencies in the request, if any, request within 60 days of the receipt of the request.; and (b) If if the competent authority of the requested Requested Party has been unable to obtain and provide the information requested within 90 days of receipt of the request, including or if it encounters obstacles are encountered in furnishing the information information, or it if the competent authority of the Requested Party refuses to furnish provide the information, it shall immediately inform the applicant Partycompetent authority of the Requesting Party in writing, explaining the reason for its inability, the nature of the obstacles or the reasons for its inability to obtain and provide the information, or the obstacles encountered, or for its refusal.