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 by the requesting Party information for the purposes referred to in Article 3. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 3, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms with the laws and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 it 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, 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, the requested Party shall shall, at its own discretion, use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, provide through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the territorial jurisdiction of the requested Party or is in the possession of or obtainable by control of a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge in writing receipt of the a request to the competent authority of the requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the requesting Party with of any deficiencies in the least possible delayrequest within 60 days of receipt of the request. 8. 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, or if obstacles are encountered in furnishing the information, or if the competent authority of the requested Party refuses to provide the information, it shall immediately inform the competent authority of the requesting Party in writing, explaining the reasons for its inability to obtain and provide the information, or the obstacles encountered or the reasons for its refusal to provide the requested information.

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 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5; in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of of, or obtainable by by, a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to of the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

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 31. 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 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 meansmeans 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, the requested that Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;; and (ib) information Information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter does not create an obligation for a Party to obtain or provide ownership ; and in the case of foundations, information with respect to publicly traded companies or public on founders, members of the foundation council and beneficiaries, collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation;, (b) the The period for which the information is requested;, (c) the The nature of the information requested sought and the form in which the requesting Party would prefer to receive it;, (d) the The tax purpose for which the information is sought;, (e) the The reasons for believing that the information requested is foreseeably relevant to tax the 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 Grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party;, (g) to To the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested;requested information, (h) a A statement that the request conforms with the laws and administrative practice of the requesting Party, Party and that if the requested information was within the jurisdiction of would be obtainable by the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the its laws of the requesting 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 Party under this Chapter; andAgreement, (i) a A statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible by specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) reasonable grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of of, or obtainable by by, a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party party shall provide upon request by the requesting Party party information for the purposes referred to in Article 31. Such information shall be exchanged without regard to whether the requested Party 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 party if it had occurred in the territory of the requested Partyparty. The competent authority of the requesting Party 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, the requested Party party shall use the take all relevant information gathering measures it considers relevant to provide the requesting Party 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. In the execution of a request by the requested party, only those privileges under the laws and practices of the requested party shall apply and any privileges under the laws and practices of the requesting party shall be reserved for resolution by the requesting party. 3. If specifically requested by the competent authority of the requesting Partyparty, 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 Party party shall ensure that it has the authority, for the purposes referred to in Article 1 of this Agreement and subject to the terms Article 2 of Article 3this Agreement, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemesfunds, information on shares, units units, and other interests; (ii) ; and in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemesfunds, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information made by a party shall be formulated framed with the greatest detail necessary and degree of specificity possible. In all cases, such requests shall specify in writing;writing the following: (a) the identity of the person taxpayer under examination or investigation; (b) the period for of time with respect to which the information is requested; (c) the nature of the information requested and the form in which the requesting Party party would prefer to receive it; (d) the matter under the requesting party’s tax purpose for law with respect to 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 Partyparty, with respect to the person identified in subparagraph (a) of this paragraph; (f) reasonable grounds for believing that the information requested is present in the requested Party party or is in the possession or control of or obtainable by a person within the jurisdiction of the requested Partyparty; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms with to the laws law and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of party and would be obtainable by the requesting Party then the competent authority of the requesting Party would be able to obtain the information party under the its laws of the requesting 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 Chapter; andAgreement; (i) a statement that the requesting Party party has pursued all reasonable means available in its own territory jurisdiction to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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 meansmeans 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, the requested that Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the its competent authority, subject to in accordance with the terms of Article 3this Agreement, has the authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;; and (ib) information Information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter ; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, provided that this Agreement does not create an obligation for a Party on the Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation; (b) the The period for which the information is requested; (c) the The nature of the information requested sought and the form in which the requesting Party would prefer to receive it; (d) the The tax purpose for which the information is sought; (e) the The reasons for believing that the information requested is foreseeably relevant to tax the 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 Grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to To the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a A statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a A statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party party shall provide upon request by the requesting Party party information for the purposes referred to in Article 1 of this Agreement and in accordance with its further provisions. 2. Any request for information made by a party shall be framed with the greatest degree of specificity possible. In all cases, such requests shall specify in writing the following: (a) the identity of the taxpayer whose tax or criminal liability is at issue; (b) the period of time with respect to which the information is requested; (c) the nature of the information requested and the form in which the requesting party would prefer to receive it; (d) the matter under the requesting party’s tax law with respect to 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested party or is in the possession or control of a person within the jurisdiction of the requested party; (g) to the extent known, the name and address of any person believed to be in possession or control of the information requested; (h) a statement that the requesting party would be able to obtain and provide the requested information if a similar request were made by the requested party; (i) a statement that the requesting party has pursued all reasonable means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 3. Such information Information shall be obtained and exchanged under this Agreement without regard to whether the requested Party 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 party if it had occurred in the territory of the requested Partyparty. The competent authority of the requesting Party party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other meansmeans available in its own territory, except where recourse to such means would give rise to disproportionate difficulty. 24. 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, the requested Party party shall use the take all relevant information gathering measures it considers relevant to provide the requesting Party 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. Privileges under the laws and practices of the requesting party shall not apply in the execution of a request by the requested party and such matters shall be reserved for resolution by the requesting party. 35. If Each party shall take all necessary measures to compel production of the information requested, and if specifically requested requested, the information shall be provided in the form specified by the competent authority of the requesting Partyparty, 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 including depositions of witnesses and authenticated copies of original recordsdocuments. 46. Each Party party shall ensure that it has the authority, for the purposes referred to in Article 1 of this Agreement and subject to the terms Article 2 of Article 3this Agreement, to obtain and provide, through its competent authority and upon a request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships companies and other personslegal entities, and including within the constraints of Article 3 any other 2 of this Agreement, information on all persons in an ownership chain, including ; (ii) in the case of collective investment schemespartnerships, information on shares, units and other interests; regarding the identities of the members of the partnership; (iiiii) in the case of trusts, information on the settlors, trusteestrustees and beneficiaries; and (iv) in the case of foundations, protectors information on the founders, members of the foundation council, and beneficiaries. 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms with the laws and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by of the requesting applicant Party information for the purposes referred to in Article 31. 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 it had such conduct occurred in the territory of the requested Party. The competent authority of the requesting applicant 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, the requested that Party shall use the all relevant information gathering measures it considers relevant to provide the requesting applicant 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 the requesting 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 it has the authorityits competent authorities, subject to in accordance with the terms of Article 3this Agreement, have the authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacitycapacity including nominees and trustees; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including including: (i) in the case of collective investment schemes, funds or schemes information on sharesthe units, units and shares or other interestsinterests in the fund or scheme; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter ; and in the case of foundations, information on founders, members of the foundation council and beneficiaries; provided that this Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall in all cases specify in writing;: (a) the identity of the person under examination or investigation; (b) the taxable period for which the information is requestedsought; (c) the nature a statement of the information requested sought including its nature and the form in which the requesting applicant Party would prefer wishes to receive itthe information from the requested Party; (d) the matter under the applicant Party’s tax purpose for law with respect to which the information is sought; (e) the reasons for believing that the information requested is foreseeably relevant to tax the administration and enforcement of the requesting domestic tax laws of the applicant Party, with respect regard to the person identified specified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is present 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; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting applicant Party, that if the requested information was within the jurisdiction of the requesting applicant Party then the competent authority of the requesting applicant Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice of the applicant Party and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting applicant Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge 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 the a request in writing to the competent authority of the requesting applicant Party and shall use its best endeavours to forward 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 requesting Party with information, it shall immediately inform the least possible delayapplicant 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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any The competent authority of the requesting Party shall provide the following information to the competent authority of the requested Party when making a request for information shall be formulated with under this Agreement to demonstrate the greatest detail necessary and shall specify in writing;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) the nature a statement of the information requested sought including its nature and the form in which the requesting Party would prefer wishes to receive itthe information from the requested Party; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge forward the requested information as promptly as possible to the requesting Party. To ensure prompt response the competent authority of the requested Party shall: (a) confirm receipt of the a request in writing to the competent authority of the requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the requesting Party with of deficiencies in the least possible delayrequest, if any, within 60 days of the receipt of the request; and (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 requesting Party thereof and explain 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 31. 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 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 meansmeans 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, the requested that Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;; and (ib) information Information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors and beneficiaries.; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation;, (b) the The period for which the information is requested;, (c) the The nature of the information requested sought and the form in which the requesting Party would prefer to receive it;, (d) the The tax purpose for which the information is sought;, (e) the 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 Grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party;, (g) to To the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested;requested information, (h) a A statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement, (i) a A statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trusteestrustees and beneficiaries; and in the case of foundations, protectors information on founders, members of the foundation council and beneficiaries. 5. This Chapter Agreement does not create an obligation 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. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use the all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries and, in the case of foundations, members of the foundation council and beneficiaries.; 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose for which the information is sought; (e) the reasons for believing that the information requested is foreseeably 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 present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

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 31. 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 it had such conduct 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, the requested Party shall use the all relevant information gathering measures it considers relevant to provide the requesting 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 requesting 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 Party shall ensure that it its competent authority, for the purposes of this Agreement, has the authority, subject to the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and including, within the constraints of Article 3 any other 2, ownership information on all such persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors beneficiaries, and beneficiariesthe position in an ownership chain; and in the case of foundations, information on founders, members of the foundation council and beneficiaries and the position in an ownership chain. 5. This Chapter Agreement does not create an obligation for a Party on the Parties to obtain or provide provide: a) ownership information with respect to publicly traded companies or public collective investment schemes, 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. 6. Any 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 shall be formulated with under this Agreement to demonstrate the greatest detail necessary and shall specify in writing;relevance of the information sought to the request: (a) the identity of the person taxpayer under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession or control of or obtainable by a person within subject to the jurisdiction of the requested Party; (gc) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (hd) a statement that the request conforms with to the laws law and administrative practice of the requesting Partyapplicant Party and would be obtainable by the applicant Party under its laws in similar circumstances, that if both for its own tax purposes and in response to a valid request from the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (ie) a statement that the requesting applicant Party has pursued all means available in its own territory Party to obtain the information, except where those that would give rise to disproportionate difficultydifficulties; 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. 79. The competent authority of the requested Party shall acknowledge 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 the a request in writing to the competent authority of the requesting applicant Party and shall use its best endeavours to forward 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 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 requesting Party with information, it shall immediately inform the least possible delayapplicant 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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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 meansmeans 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, the requested that Contracting Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the 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 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 it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;, (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter ; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, provided that this Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 6. (5) Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation;, (b) the period for which the information is requested;, (c) the nature of the information requested sought and the form in which the requesting Contracting Party would prefer to receive it;, (d) the tax purpose for which the information is sought;, (e) the reasons for believing that the information requested is foreseeably relevant to the tax 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 present held in the requested Contracting Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Contracting Party;, (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested;requested information, (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Contracting Party, that if the requested information was within the jurisdiction of the requesting Contracting Party then the competent authority of the requesting Contracting Party would be able to obtain the information under the laws of the requesting Contracting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement, (i) a statement that the requesting Contracting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. (6) The competent authority of the requested Contracting Party shall acknowledge receipt of the request to the competent authority of the requesting Contracting Party and shall use its best endeavours to forward the requested information to the requesting Contracting Party with the least possible reasonable delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by the requesting re- questing Party information for the purposes referred to in Article 31. 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 it had occurred in the territory of the requested Party. The competent authority au- thority of the requesting Party shall only make a request for information pursuant to this Article Arti- cle when it is unable to obtain the requested information by other meansmeans 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, the requested that Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the requesting re- questing 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 the requesting Party, the competent compe- tent 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 Party shall ensure that it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;, (ib) information Information regarding the legal and beneficial ownership of companies, partnerships partner- ships and other personspersons and, and within the constraints of Article 3 2, any other persons in an ownership chain, including in including i) In the case of collective investment funds and schemes, information on shares, units and other interests; (ii) in In the case of trusts, information on settlors, trustees, trustees protectors and benefici- aries; and iii) In the case of foundations, information on founders, members of the founda- tion council and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, invest- ment funds or schemes unless such information can be obtained without giving rise to disproportionate dispro- portionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation;, (b) the The period for which the information is requested;, (c) the The nature of the information requested sought and the form in which the requesting Party would prefer to receive it;, (d) the The tax purpose for which the information is sought;, (e) the The reasons for believing that the information requested is foreseeably relevant to tax the administration and enforcement of the tax law of the requesting Party, with respect re- spect to the person identified in subparagraph (a) of this paragraph;, (f) grounds Grounds for believing that the information requested is present held in the requested Party or is in the possession of or in the control of or obtainable by a person within the jurisdiction of the requested Party;, (g) to To the extent known, the name and address of any person believed to be in possession posses- sion of or in the control of or able to obtain the information requested;requested information, (h) a A statement that the request conforms with the laws and administrative practice of the requesting Party, Party and that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain obtainable by the information request- ing Party under the its laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with re- sponse to a valid request made in similar circumstances from the requested Party under this Chapter; andAgreement, (i) a A statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydispropor- tionate difficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacity, including nominees and trustees,; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 1, any other persons in an ownership chain, ; including in the case of collective investment funds or schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries.; and 5. This Chapter (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries, provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any The competent authority of the requesting Party shall provide the following information to the competent authority of the requested Party when making a request for information shall be formulated with under this Agreement to demonstrate the greatest detail necessary and shall specify in writing;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) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 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 requesting Party within 30 days of the receipt of the request and shall notify the competent authority of the 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the 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 Party shall provide upon request by the requesting Party information for the purposes referred to in Article 31. 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 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, the requested Party shall use the all appropriate information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, trusts, foundations, and other persons, and including, within the constraints of Article 3 any other persons in an 1, ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) all such persons; in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter ; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, and in all such cases ownership information on all such persons in an ownership chain; provided that this Agreement does not create an obligation 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. 65. Any In order to facilitate the processing of a request for information by the requested Party the requesting Party shall be formulated formulate the request with the greatest detail necessary and necessary. The request shall specify in writing;: (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) the period for which the information is requested; (cd) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (de) the tax purpose for which the information is sought, including: (i) the legal authority under the requesting Party’s tax law with respect to which the information is sought; and (ii) whether the matter is a criminal tax matter; (ef) 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; (fg) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (gh) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (hi) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (ij) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party Party, shall advise if there are any expected delays in obtaining the requested information and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by of the requesting applicant Party information for the purposes referred to in Article 31. 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 it had such conduct occurred in the territory of the requested Party. The competent authority of the requesting applicant Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other meansmeans available 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, the requested that Party shall use the all relevant information gathering measures it considers relevant to provide the requesting 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 requesting 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 it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacitycapacity including nominees and trustees; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including including, (i) in the case of collective investment schemes, funds or schemes information on sharesthe units, units and shares or other interestsinterests in the fund or scheme; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter ; and in the case of foundations and enterprises (ìAnstalten”), information on founders, members of the foundation council and beneficiaries; provided that this Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any The competent authority of the applicant Party shall formulate the request for information shall be formulated with the greatest detail necessary possible and shall specify provide the following information to the competent authority of the requested Party in writing;writing 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 requestedsought; (c) the nature a statement of the information requested sought including its nature and the form in which the requesting applicant Party would prefer wishes to receive itthe information from the requested Party; (d) the tax purpose for which the information is sought; (e) the reasons grounds for believing that the information requested is foreseeably relevant to tax the administration and enforcement of the requesting Party, domestic tax laws of the applicant Party with respect regard to the person identified specified in subparagraph (a) of this paragraph); (f) grounds for believing that the information requested is present 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; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting applicant Party, that if the requested information was within the jurisdiction of the requesting applicant Party then the competent authority of the requesting applicant Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice of the applicant Party and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting applicant Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge 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 the a request in writing to the competent authority of the requesting applicant Party and shall use its best endeavours to forward notify the competent authority of the applicant Party of deficiencies in the request, if any, within sixty (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 ninety (90) days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the requesting Party with information, it shall immediately inform the least possible delayapplicant 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 in writing by the requesting Party party information for the purposes referred to in Article 31. 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 it had occurred in the territory of the requested Partyparty. The 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 shall only make a request for party of that fact with suggestions of the additional information pursuant required to this Article when it is unable to obtain enable the requested information by other means, except where recourse to such means would give rise to disproportionate difficultyeffective 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 information, the requested Party party shall use the take all relevant information gathering measures it considers relevant to provide the requesting Party 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 the requesting Partyparty, 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 Party party shall ensure that it its competent authority, for the purposes of this Agreement, has the authority, subject to the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter does not create an obligation for The competent authority of the requesting party shall provide the following information to the competent authority of the requested party when making a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with under this Agreement in order to demonstrate the greatest detail necessary and shall specify in writing;relevance of the information sought to the request: (a) the name of the authority seeking the information or conducting the investigation or proceeding to which the request relates; (b) the identity of the person taxpayer under examination or investigation; (b) the period for which the information is requested; (c) the nature and type of the information requested and requested, including a description of the form in which the requesting Party would prefer to receive itspecific evidence, information or other assistance sought; (d) the tax purpose purposes for which the information is sought; (e) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement period of the requesting Party, time with respect to which the person identified in subparagraph (a) of this paragraphinformation is requested; (f) reasonable grounds for believing that the information requested is present in the territory of the requested Party party or is in the possession or control of or obtainable by a person within subject to the jurisdiction of the requested Partyparty and may be relevant to the tax purposes of the request; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement declaration that the request conforms with to the laws law and administrative practice of the requesting Partyparty and would be obtainable by the requesting party under its laws in similar circumstances, that if both for its own tax purposes and in response to a valid request from the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information party under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficultyAgreement. 76. The competent authority of the requested Party party shall acknowledge receipt of forward the request requested information as promptly as possible to the competent authority of the requesting Party 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 requesting party, and shall use its best endeavours to forward notify the competent authority of the requesting party of any deficiencies in the request within 60 days of receipt of the request; (b) if the competent authority of the requested party has been unable to obtain and provide the information requested within a reasonable period relative to the nature of the request, or if obstacles are encountered in furnishing the information, or if the competent authority of the requested party refuses to provide the information, it shall immediately inform the competent authority of the requesting Party with party to explain the least possible delayreasons for its inability or the obstacles or its refusal.

Exchange of Information Upon Request. 1. The competent authority of the requested Party party shall provide upon request by the requesting Party party information for the purposes referred to in Article 31. Such information shall be exchanged without regard to whether the requested Party 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 it had occurred in the territory of the requested Partyparty. The competent authority of the requesting Party 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, the requested Party party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary to provide the requesting Party 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 the requesting Partyparty, 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 Party party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Provided that this Agreement does not create an obligation for a Party party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party party would prefer to receive it; (d) 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 Partyparty, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party party or is in the possession of of, or obtainable by by, a person within the jurisdiction of the requested Partyparty; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Partyparty, that if the requested information was within the jurisdiction of the requesting Party party then the competent authority of the requesting Party party would be able to obtain the information under the laws of the requesting Party party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party party shall acknowledge receipt of the request to the competent authority of the requesting Party party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayparty as soon as possible.

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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) : information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) 1. information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) 1. information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) 2. in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) 1. the identity of the person under examination or investigation; (b) 2. the period for which the information is requested; (c) 3. the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 4. the tax purpose for which the information is sought; (e) 5. 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) 6. grounds for believing that the information requested is present in the requested Party or is in the possession of of, or obtainable by by, a person within the jurisdiction of the requested Party; (g) 7. to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) 8. a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) 9. a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

Exchange of Information Upon Request. (1. ) The competent authority of the requested Party shall provide upon request by of the requesting applicant Party information for the purposes referred to in Article 31. 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 it had such conduct occurred in the territory of the requested Party. The competent authority of the requesting applicant Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other meansmeans available 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, the requested that Party shall use the all relevant information gathering measures it considers relevant to provide the requesting applicant 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 the requesting 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 it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacitycapacity including nominees and trustees; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests;including, (iibb) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries.; and in the case of foundations, information on founders, members of the foundation council and beneficiaries; (5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. ) Any request for information shall be formulated with the greatest detail necessary possible and shall in all cases specify in writing;: (a) the identity of the person under examination or investigation; (b) the taxable period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose 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; d) the matter under the applicant Party’s tax law with respect to which the information is sought; e) the reasons grounds for believing that the information requested is foreseeably relevant to tax the administration and enforcement of the requesting Party, domestic tax laws of the applicant Party with respect regard to the person identified specified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is present 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; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting applicant Party, that if the requested information was within the jurisdiction of the requesting applicant Party then the competent authority of the requesting applicant Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice of the applicant Party and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting applicant Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. (6) The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting applicant Party and shall use its best endeavours within its means to forward the requested information to the requesting applicant Party with the least possible reasonable 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 party information for the purposes referred to in Article 31. 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 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. 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 2. If the information in possession of the competent authority of the requested Party party is not sufficient to enable it to comply with the request for the information, the requested party shall use the all relevant information gathering measures it considers relevant to provide the requesting Party 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 the requesting Partyparty, 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 Party contracting party shall ensure that it its competent authority, for the purposes of this Agreement, has the authority, subject to the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, trusts and other persons, and including, within the constraints of Article 3 any other 2, ownership information on all such persons in an ownership chain, including in the case of collective investment schemes, information on shares, units ; and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors beneficiaries and beneficiariesprotectors. 5. This Chapter Notwithstanding the preceding paragraphs, this Agreement does not create an obligation for a Party on the contracting parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, schemes unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any The competent authority of the requesting party shall provide the following information to the competent authority of the requested party when making a request for information shall be formulated with under this Agreement in order to demonstrate the greatest detail necessary and shall specify in writing;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) the nature and type of the information requested requested, including a description of the specific evidence sought and the form in which the requesting Party party would prefer to receive itthe information; (d) the tax purpose purposes for which the information is sought; (e) sought and the reasons for believing that the information requested is foreseeably relevant to tax the administration and or enforcement of the domestic laws of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraphparty; (fe) reasonable grounds for believing that the information requested is present in the territory of the requested Party party or is in the possession or control of or obtainable by a person within subject to the jurisdiction of the requested Partyparty; (gf) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (hg) a statement that the request conforms is in conformity with this Agreement and the laws and administrative practice practices of the requesting Partyparty, and that if the requested information was were within the jurisdiction of the requesting Party party then the competent authority of the requesting Party party would be able to obtain the information under the laws of the requesting Party party or in the normal course of administrative practice and that it is in conformity with this Chapter; andpractice; (ih) a statement that the requesting Party territory has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. The competent authority of the requested Party party shall acknowledge receipt of forward the request requested information as promptly as possible to the competent authority of the requesting Party party. 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 requesting party and shall use its best endeavours to forward notify the competent authority of the requesting party of any deficiencies in the request within 60 days of receipt of the request; and (b) 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 obstacles are encountered in furnishing the information, or if the competent authority of the requested party refuses to provide the information, it shall immediately inform the competent authority of the requesting Party with party to explain the least possible delayreasons 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 by the requesting Party information for the purposes referred to in Article 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Further, this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to of the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

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 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has its competent authorities for the authority, subject to purposes specified in Article 1 and within the terms constraints of Article 32 of the Agreement, have the authority to obtain and provide, through its competent authority and provide upon request: (a) a. information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, and other persons, and within the constraints of Article 3 any other including ownership information on all such persons in an ownership chain; (ii) in the case of trusts, including information on settlors, trustees and beneficiaries; (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries; and (iv) in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter ; provided that this Agreement does not create an obligation for a on either Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, Investment schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest as much detail necessary as possible and shall specify in writing;: (a) a. the identity of the person under examination or investigation; (b) b. the period for which the information is requested; (c) c. the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) d. the tax purpose for which the information is sought; (e) 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 (a) of this paragraph; (f) f. the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) g. to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) h. a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) i. a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use at its own discretion the information gathering measures measure it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, persons and within the constraints of Article 3 any other persons in an ownership chain, including including: (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, protectors and beneficiaries; and (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms with the laws and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall at its own discretion use the all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject for the purposes referred to the terms of in Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter , Provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 1. With reasonable notice, the requesting Party may request that the requested Party allow representatives of the competent authority of the requesting Party to enter the territory of the requested Party, to the extent permitted under its domestic laws, to interview individuals and examine records with the prior written consent of the individuals or other persons concerned. The competent authority of the requesting Party shall notify the competent authority of the requested Party of the time and place of the intended meeting with the individuals concerned. 2. At the request of the competent authority of the requesting Party, the competent authority of the requested Party may permit representatives of the competent authority of the requesting Party to attend a tax examination in the territory of the requested Party. 3. If the request referred to in paragraph 2 is granted, the competent authority of the requested Party conducting the examination shall, as soon as possible, notify the competent authority of the requesting Party of the time and place of the examination, the authority or person authorised to carry out the examination and the procedures and conditions required by the requested Party for the conduct of the examination. All decisions regarding the conduct of the examination shall be made by the requested Party conducting the examination.

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 31. 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 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 meansmeans 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, the requested Party shall use the all relevant information gathering measures it considers relevant necessary 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, 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 it has its competent authorities for the authoritypurposes specified in Article 1 of the Agreement, subject to have the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 2 any other persons person in an ownership chain, including in the case of collective investment funds or schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries; and (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. The competent authority of the requested Party shall acknowledge forward the requested information as promptly as possible to the requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: a) confirm receipt of the a request in writing to the competent authority of the requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the requesting Party with of deficiencies in the least possible delayrequest, 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 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 31. 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 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 meansmeans 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, the requested that Contracting Party shall use the all relevant information gathering measures it considers relevant necessary 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, 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 it has its competent authorities have the authority, subject to the terms of Article 31, and within the constraints of Article 2, to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations, and other persons, and within the constraints of Article 3 any other including ownership information on all such persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers, beneficiaries and the trust property; (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested sought and the form in which the requesting Party would prefer wishes to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it the request is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 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 requesting Party and shall notify the competent authority of the requesting Party of deficiencies in the request, if any, within 60 days of the receipt of the request; and b) if the competent authority of the requested Party has been unable to obtain and provide the information within 180 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 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 Party shall provide upon request by the requesting Party information for the purposes referred to in Article 31. 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 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, the requested Party shall at its own discretion use the all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject for the purposes referred to the terms of in Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries., 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of of, or obtainable by by, a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

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 31. 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 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, the requested Party shall use the all appropriate information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, trusts, foundations, and other persons, and including, within the constraints of Article 3 any other persons in an 1, ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) all such persons; in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter ; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, and in all such cases ownership information on all such persons in an ownership chain; provided that this Agreement does not create an obligation 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. 65. Any In order to facilitate the processing of a request for information by the requested Party the requesting Party shall be formulated formulate the request with the greatest detail necessary and necessary. The request shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

Exchange of Information Upon Request. (1. ) The competent authority of the requested Party shall provide upon request by of the requesting applicant Party information for the purposes referred to in Article 31. 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 it had such conduct occurred in the territory of the requested Party. The competent authority of the requesting applicant Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other meansmeans available 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, the requested that Party shall use the all relevant information gathering measures it considers relevant to provide the requesting applicant 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 the requesting 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 it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacitycapacity including nominees and trustees; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including including, i) in the case of collective investment schemes, funds or schemes information on sharesthe units, units and shares or other interestsinterests in the fund or scheme; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter ; and in the case of foundations, information on founders, members of the foundation council and beneficiaries; provided that this Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 6. (5) Any request for information shall be formulated with the greatest detail necessary possible and shall in all cases specify in writing;: (a) the identity of the person under examination or investigation; (b) the taxable period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose 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; d) the matter under the applicant Partyís tax law with respect to which the information is sought; e) the reasons grounds for believing that the information requested is foreseeably relevant to tax the administration and enforcement of the requesting Party, domestic tax laws of the applicant Party with respect regard to the person identified specified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is present 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; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting applicant Party, that if the requested information was within the jurisdiction of the requesting applicant Party then the competent authority of the requesting applicant Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice of the applicant Party and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting applicant Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. (6) The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting applicant Party and shall use its best endeavours within its means to forward the requested information to the requesting applicant Party with the least possible reasonable delay.

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 31. 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 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, the requested Party shall use the all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries and, in the case of foundations, members of the foundation council and beneficiaries. 5. This Chapter ; provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose for which the information is sought; (e) the reasons for believing that the information requested is foreseeably 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 present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 72. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

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 31. 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 it had such conduct 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 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, the requested Party shall use the all relevant information gathering measures it considers relevant necessary 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, 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 it has the authority, subject to in accordance with the terms of Article 3this agreement, to obtain and provide, through its competent authority and authority, upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, collective investment funds or schemes, trusts, foundations, “Anstalten” and other persons, and including, within the constraints of Article 3 any other 2, ownership information on all such persons in an ownership chain, including ; c) in the case of collective investment funds or schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries; 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. This Chapter Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any The competent authority of the requesting Party shall provide the following information to the competent authority of the requested Party when making a request for information shall be formulated with under the greatest detail necessary and shall specify in writing;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) the nature of the information requested and the form in which the requesting Party would prefer to receive itit ; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of, or is in the control of or obtainable by by, a person within the jurisdiction of the requested Party; (gf) to the extent known, the name and address of any person believed to be in possession or in control of or able to obtain the information requestedrequested information; (hg) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (ih) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours endeavors to forward the requested information as promptly as possible to the requesting Party with the least possible delayParty.

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 31. 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 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, the requested Party shall use the use, at its own discretion, all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject for the purposes referred to the terms of in Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries.; 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and or beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries and, in the case of foundations, members of the foundation council and beneficiaries. 5. This Chapter ; provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose for which the information is sought; (e) the reasons for believing that the information requested is foreseeably 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 present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

Exchange of Information Upon Request. 1. The competent authority of the requested Party shall provide upon request by of the requesting applicant Party information for the purposes referred to in Article 31. 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 it had such conduct occurred in the territory of the requested Party. The competent authority of the requesting applicant Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other meansmeans available 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, the requested Party shall use the information gathering measures it considers relevant to provide the requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes.to 3. If specifically requested by the competent authority of the requesting 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 it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacitycapacity including nominees and trustees; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests;including, (iibb) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries.; and in the case of foundations, information on founders, members of the foundation council and beneficiaries; 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall in all cases specify in writing;: (a) the identity of the person taxpayer under examination or investigation; (b) the taxable period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose 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; d) the matter under the applicant Party’s tax law with respect to which the information is sought; e) the reasons grounds for believing that the information requested is foreseeably relevant to tax the administration and enforcement of the requesting Party, domestic tax laws of the applicant Party with respect regard to the person identified specified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is present 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; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting applicant Party, that if the requested information was within the jurisdiction of the requesting applicant Party then the competent authority of the requesting applicant Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice of the applicant Party and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting applicant Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty.own 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting applicant Party and shall use its best endeavours within its means to forward the requested information to the requesting applicant Party with the least possible reasonable delay.

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 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) a. information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5, including those persons to whom the title to trust property may be transferred upon the ending of the trust. This Chapter Notwithstanding the foregoing, this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) a. the identity of the person under examination or investigation; (b) b. the period for which the information is requested; (c) c. the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) d. the tax purpose for which the information is sought; (e) 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 (a) a. of this paragraph; (f) f. the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) g. to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) h. a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the its laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) i. a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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 meansmeans 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, the requested that Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;; and (ib) information Information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors and beneficiaries.; 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation;, (b) the The period for which the information is requested;, (c) the The nature of the information requested sought and the form in which the requesting Party would prefer to receive it;, (d) the The tax purpose for which the information is sought;, (e) the 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 Grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party;, (g) to To the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested;requested information, (h) a A statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement, (i) a A statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has its competent authorities, for the authoritypurposes specified in Article 1 of the Agreement, subject to have the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacitycapacity including nominees and trustees; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations, and other persons, and within the constraints of Article 3 any other including, ownership information on all such persons in an ownership chain, including ; (ii) in the case of collective investment funds or schemes, information on shares, units and other interests; (iiiii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries.; 5(iv) in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Agreement does not create an obligation 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. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present or held in the requested Party or is in the possession of, under the control of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of, in the control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge forward the requested information as promptly as possible to the requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: (a) confirm receipt of the a request in writing to the competent authority of the requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the requesting Party with of deficiencies in the least possible delayrequest, 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information it shall immediately inform the 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 Party shall provide upon request by the requesting Party information for the purposes referred to in Article 31. 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 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 meansmeans 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, the requested that Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it its competent authority for the purposes specified in Article 1 and subject to Article 2 of this Agreement, has the authority, subject to the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;; and (ib) information Information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter ; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation; (b) the The period for which the information is requested; (c) the The nature of the information requested sought and the form in which the requesting Party would prefer to receive it; (d) the The tax purpose for which the information is sought; (e) the The reasons for believing that the information requested is foreseeably relevant to the tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds Grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party;, (g) to To the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a A statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a A statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 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 requesting Party within 30 days of the receipt of the request and shall notify the competent authority of the 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the 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 Party shall provide upon request by the requesting Party information for the purposes referred to in Article 31. 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 it had such conduct 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has its competent authorities, for the authoritypurposes specified in Article 1 and in accordance with Article 2 of the Agreement, subject to have the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, and other persons, and within the constraints of Article 3 any other including ownership information on all such persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries.; 5. This Chapter (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries; and (iv) in the case of collective investment schemes, information on shares, units and other interests; provided that this Agreement does not create an obligation for a on either Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest as much detail necessary as possible and shall specify in writing;: (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 referred to in subparagraph (ba); c) the period for which the information is requested; (cd) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (de) the tax purpose for which the information is sought, including: (i) the citation of the legal authority under the requesting Party’s tax or other law with respect to which the information is sought; and (ii) whether the matter is a criminal tax matter; (ef) 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; (fg) grounds for believing that the information requested is present in held by the requested Party or is in the possession of or in the control of or obtainable by a person within the territorial jurisdiction of the requested Party; (gh) to the extent known, the name and address of any person believed to be in the possession of or in the control of or able to obtain the information requestedrequested information; (hi) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party Party, then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice practice, and that it the request is in conformity with this Chapter; andAgreement; (ij) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacitycapacity including nominees and trustees; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 1 any other persons in an ownership chain, including in the case of collective investment funds or schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries.; and 5. This Chapter (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries, provided that this Agreement does not create an obligation 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. 65. Any The competent authority of the requesting Party shall provide the following information to the competent authority of the requested Party when making a request for information shall be formulated with under this Agreement to demonstrate the greatest detail necessary and shall specify in writing;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) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 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 requesting Party within 30 days of the receipt of the request and shall notify the competent authority of the 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the 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 Party party shall provide upon request by the requesting Party party information for the purposes referred to in Article 3Article 1. Such information shall be exchanged without regard to whether the requested Party 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 it had occurred in the territory of the requested Partyparty. The competent authority of the requesting Party 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, the requested Party party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary to provide the requesting Party 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 the requesting Partyparty, 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 Party party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party party would prefer to receive it; (d) 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 Partyparty, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party party or is in the possession of or obtainable by a person within the jurisdiction of the requested Partyparty; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Partyparty, that if the requested information was within the jurisdiction of the requesting Party party then the competent authority of the requesting Party party would be able to obtain the information under the laws of the requesting Party party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party party shall acknowledge receipt of the request to the competent authority of the requesting Party party and shall use its best endeavours to forward the requested information to the requesting Party party with the least possible reasonable delay.

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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries., 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 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 requesting Party and shall notify the competent authority of the 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the 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 Party shall provide upon request by the requesting Party information for the purposes referred to in Article 31. 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 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, the requested Party shall use the use, at its own discretion, all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the [legal and and] beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries [and, in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. This Chapter ]; provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of of, or obtainable by by, a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay. 1. With reasonable notice, the requesting Party may request that the requested Party allow representatives of the competent authority of the requesting Party to enter the territory of the requested Party, to the extent permitted under its domestic laws, to interview individuals and examine records with the written consent of the individuals or other persons concerned. The competent authority of the requesting Party shall notify the competent authority of the requested Party of the time and place of the intended meeting with the individuals concerned. 2. At the request of the competent authority of the requesting Party, the competent authority of the requested Party may permit representatives of the competent authority of the requesting Party to attend a tax examination in the territory of the requested Party. 3. If the request referred to in paragraph 2 is granted, the competent authority of the requested Party conducting the examination shall, as soon as possible, notify the competent authority of the requesting Party of the time and place of the examination, the authority or person authorised to carry out the examination and the procedures and conditions required by the requested Party for the conduct of the examination. All decisions regarding the conduct of the examination shall be made by the requested Party conducting the examination.

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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (iic) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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 meansmeans 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, the requested that Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;, (ib) information Information regarding the legal and beneficial ownership of companies, partnerships and other personspersons and, and within the constraints of Article 3 2, any other persons in an ownership chain, including in including i) In the case of collective investment funds and schemes, information on shares, units and other interests; (ii) in 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, 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation;, (b) the The period for which the information is requested;, (c) the The nature of the information requested sought and the form in which the requesting Party would prefer to receive it;, (d) the The tax purpose for which the information is sought;, (e) the The reasons for believing that the information requested is foreseeably relevant to tax the 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 Grounds for believing that the information requested is present held in the requested Party or is in the possession of or in the control of or obtainable by a person within the jurisdiction of the requested Party;, (g) to To the extent known, the name and address of any person believed to be in possession of or in the control of or able to obtain the information requested;requested information, (h) a A statement that the request conforms with the laws and administrative practice of the requesting Party, Party and that if the requested information was within the jurisdiction of would be obtainable by the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the its laws of the requesting 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 Party under this Chapter; andAgreement, (i) a A statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

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 3. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 3, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms with the laws and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; and (i) and a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 it had such conduct 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 only if it is unable would not be able to obtain the information requested information by other means, except where recourse to such means that would give rise to disproportionate difficultydifficulties. 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, the requested Party shall use the all relevant information gathering measures it considers relevant necessary to provide the requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes. Privileges under the laws and practices of the requesting Party shall not apply in the execution of a request by the requested Party and the resolution of such matters shall be solely the responsibility of the requesting Party. 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, for the purposes referred to in Article 1 and subject to the terms of Article 32, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;; and (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, trusts, foundations and other persons, and including, within the constraints of Article 3 any other 2, ownership information on all such persons in an ownership chain, including ; in the case of collective investment schemes, information on shares, units and other interests; (ii) ; in the case of foundations, information on founders, members of foundation councils and beneficiaries; and in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter However, this Agreement does not create an obligation for a Party on the Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary degree of specificity possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose for which the information is sought; (e) the reasons grounds 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 present in the requested Party or is in the possession or control of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws law and administrative practice of the requesting Party, that if Party and the requested information was within the jurisdiction of would be obtainable by the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the its laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with similar circumstances, in response to a valid request from the requested Party under this ChapterAgreement; and (i) a statement that the requesting Party has pursued all means available in its own territory jurisdiction to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use at its own discretion the information gathering measures measure it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, persons and within the constraints of Article 3 any other persons in an ownership chain, including including: in the case of collective investment schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors and beneficiaries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms with the laws and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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 has pursued all means available in its own territory to obtain the requested information by other meansinformation, except where recourse to such means those that would give rise to disproportionate difficultydifficulties. 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, the requested Party shall use the all appropriate information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to for the terms of purposes specified in Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations, and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds or schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter ; provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) a. information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing; (a) a. the identity of the person under examination or investigation; (b) b. the period for which the information is requested; (c) c. the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) d. the tax purpose for which the information is sought; (e) 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 (a) of this paragraph; (f) f. grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) g. to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) h. a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) i. a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible reasonable delay.

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 31. 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 it 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 meansmeans 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, the requested that Party shall use the all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it its competent authority has the authorityauthority for the purposes specified in Article 1, subject to and within the terms limitations of Article 32, to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations, and other persons, and within the constraints of Article 3 any other including ownership information on all such persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries.; and 5(iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Provided that this Agreement does not create an obligation for a Party on the Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requestedsought; (c) the nature of the information requested sought and the form in which the requesting Party would prefer wishes to receive it; (d) 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 (a) of this paragraph; (e) the tax purpose for which the information is sought; f) the grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws law and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge forward the requested information as promptly as possible to the requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: a) confirm receipt of the a request in writing to the competent authority of the requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the requesting Party with of deficiencies in the least possible delayrequest, 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the requesting Party, explaining the reasons 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 31. 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 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, the requested Party shall use the all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 3Articles 1 and 2 of this Agreement, to obtain and provide, provide through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations, and other persons, and within the constraints of Article 3 any other persons in an ownership chainincluding, including in the case of collective investment funds or schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries.; and 5. This Chapter iii) in the case of foundations, information on the founders, members of the foundation council and beneficiaries, provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information as promptly as possible to the requesting Party with the least possible delayParty.

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 31. 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 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 meansmeans 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, the requested Party shall use the all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. (4. ) Each Party shall ensure that it has the authority, subject to the terms of Article 31, and within the constraints of Article 2, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests;, (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries., 5. This Chapter (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries, provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 6. (5) Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose for which the information is sought; (e) the reasons for believing that the information requested is foreseeably relevant to tax the administration and enforcement of the tax laws of the requesting Party, with respect to the person identified in subparagraph (subparagraph a) of this paragraph; (f) grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. (6) The competent authority of the requested Party shall shall: a) acknowledge receipt of the request in writing to the competent authority of the requesting Party and shall use its best endeavours to forward should notify them of any deficiencies in the 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 the receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall inform the requesting Party with Party, explaining the least possible delayreason(s) for its inability, the nature of the obstacles or the reasons for its refusal; c) provide the information no later than 6 months following the date of confirmation of receipt of the request, provided that where circumstances require, both competent authorities may agree on a longer deadline. (7) The time conditions mentioned in this Article do not in any way impact on the validity and legality of information exchanged under this Agreement.

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 31. 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 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 meansmeans 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, the requested that Party shall use the at its own discretion all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;; and (ib) information Information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors and beneficiaries.; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation; (b) the The period for which the information is requested; (c) the The nature of the information requested sought and the form in which the requesting Party would prefer to receive it; (d) the The tax purpose for which the information is sought; (e) the 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 Grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to To the extent known, the name and address of any person believed to be in possession of or able to obtain the information requestedrequested information; (h) a A statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a A statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge receipt of forward the request requested information as promptly as possible to the competent authority of the requesting Party and shall use its best endeavours to forward ensure a prompt response, the competent authority of the requested information Party shall: a) Confirm the receipt of a request in writing to the requesting competent authority of the Requesting Party with and shall notify the least possible delaycompetent authority of the Requesting Party of any deficiencies in the request within 60 days of 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, it shall inform the Requesting Party, explaining the reason for its inability.

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 31. 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 it had occurred oc- curred 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 Ar- ticle when it is unable to obtain the requested information by other meansmeans in its own xxxxx- xxxx, 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 Con- tracting Party is not sufficient to enable it to comply with the request for information, the requested that Contracting Party shall use the at its own discretion all applicable information gathering measures it considers relevant meas- ures necessary to provide the requesting Contracting Party with the information requested, notwithstanding that the requested Contracting Party may not not, at that time, need such information in- formation for its own tax purposes. (3. ) If specifically requested by the competent authority of 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 it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;, (b) i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and benefici- aries; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained ob- tained without giving rise to disproportionate difficulties. 6. (5) Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation;, (b) the period for which the information is requested;, (c) the nature of the information requested sought and the form in which the requesting Contract- ing Party would prefer to receive it;, (d) the tax purpose for which the information is sought;, (e) the reasons for believing that the information requested is foreseeably relevant to the tax 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 present held in the requested Con- tracting Party or is in the possession of or obtainable by a person within the jurisdiction jurisdic- tion of the requested Contracting Party;, (g) to the extent known, the name and address of any person believed to be in possession posses- sion of or able to obtain the information requested;requested information, (h) a statement that the request conforms is in conformity with the laws and administrative practice prac- tices of the requesting Contracting Party, that if the requested information was within the jurisdiction of the requesting Contracting Party then the competent authority au- thority of the requesting Contracting Party would be able to obtain the information under the laws of the requesting Contracting Party or in the normal course of administrative admin- istrative practice and that it is in conformity with this Chapter; and (Agreement, i) a statement that the requesting Contracting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydis- proportionate difficulties. 7. (6) The competent authority of the requested Contracting Party shall acknowledge receipt of the request to the competent authority of the requesting Contracting Party and shall use its best endeavours to forward the requested information to the requesting Contracting Party with the least possible reasonable delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Party party shall provide upon request by the requesting Party party information for the purposes referred to in Article 1 of this Agreement and in accordance with its further provisions. 2. Any request for information made by a party shall be framed with the greatest degree of specificity possible. In all cases, such requests shall specify in writing the following: (a) the identity of the taxpayer whose tax or criminal liability is at issue; (b) the period of time with respect to which the information is requested; (c) the nature of the information requested and the form in which the requesting party would prefer to receive it; (d) the matter under the requesting party’s tax law with respect to 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested party or is in the possession or control of a person within the jurisdiction of the requested party; (g) to the extent known, the name and address of any person believed to be in possession or control of the information requested; (h) a statement that the requesting party would be able to obtain and provide the requested information if a similar request were made by the requested party; (i) a statement that the requesting party has pursued all reasonable means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 3. Such information Information shall be obtained and exchanged under this Agreement without regard to whether the requested Party 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 party if it had occurred in the territory of the requested Partyparty. The competent authority of the requesting Party party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other meansmeans available in its own territory, except where recourse to such means would give rise to disproportionate difficulty. 24. 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, the requested Party party shall use the take all relevant information gathering measures it considers relevant to provide the requesting Party 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. Privileges under the laws and practices of the requesting party shall not apply in the execution of a request by the requested party and such matters shall be reserved for resolution by the requesting party. 35. If Each party shall take all necessary measures to compel production of the information requested, and if specifically requested requested, the information shall be provided in the form specified by the competent authority of the requesting Partyparty, 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 including depositions of witnesses and authenticated copies of original recordsdocuments. 46. Each Party party shall ensure that it has the authority, for the purposes referred to in Article 1 of this Agreement and subject to the terms Article 2 of Article 3this Agreement, to obtain and provide, through its competent authority and upon a request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships companies and other personslegal entities, and including within the constraints of Article 3 any other 2 of this Agreement, information on all persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of partnerships, information regarding the identities of the members of the partnership; (iii) in the case of trusts, information on the settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms with the laws and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; and (iiv) a statement that in the requesting Party has pursued all means available in its own territory to obtain case of foundations, information on the informationfounders, except where that would give rise to disproportionate difficulty. 7. The competent authority members of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party foundation council, and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delaybeneficiaries.

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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ia) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (iic) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

Exchange of Information Upon Request. 1. The competent authority of the requested Requested Party shall provide upon request by the requesting Requesting Party information for the purposes referred to in Article 3Article 1. Such information shall be exchanged without regard to whether the requested 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 Requested Party if it had occurred in the territory of the requested Requested Party. The competent authority of the requesting 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 Requested Party is not sufficient to enable it to comply with the request for information, the requested Requested Party shall use the take all relevant information gathering measures it considers relevant to provide the requesting Requesting Party with the information requested, notwithstanding that the requested Requested Party may not not, at that time, 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 and any privileges under the laws and practices of the Requesting Party shall be reserved for resolution by the Requesting Party. 3. If specifically requested by the competent authority of the requesting 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 Party shall ensure that it has the authority, for the purposes referred to in Article 1 of this Agreement and subject to the terms Article 2 of Article 3this Agreement, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemesfunds, information on shares, units units, and other interests; (ii) ; and in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemesfunds, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information made by a Party shall be formulated framed with the greatest detail necessary and degree of specificity possible. In all cases, such requests shall specify in writing;writing the following: (a) the identity of the person taxpayer under examination or investigation; (b) the period for of time with respect to which the information is requested; (c) the nature of the information requested and the form in which the requesting Requesting Party would prefer to receive it; (d) the matter under the Requesting Party’s tax purpose for law with respect to 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 Requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) reasonable grounds for believing that the information requested is present in the requested Requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms with to the laws law and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of the requesting Requesting Party then the competent authority of the requesting Party and would be able to obtain obtainable by the information Requesting Party under the its laws of the requesting 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 Chapter; andAgreement; (i) a statement that the requesting Requesting Party has pursued all reasonable means available in its own territory jurisdiction to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Requested Party shall acknowledge forward the requested information as soon as reasonably possible to the Requesting Party. To ensure a prompt response, the competent authority of the Requested Party shall: (a) confirm receipt of the a request in writing to the competent authority of the requesting Requesting Party and shall use notify the competent authority of the Requesting Party of deficiencies in the request, if any, within sixty (60) days of the receipt of the request; and (b) if the competent authority of the Requested Party has been unable to obtain and provide the information within ninety (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 Requesting Party, explaining the reason for its best endeavours to forward inability, the requested information to nature of the requesting Party with obstacles or the least possible delayreasons 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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31 and 2 of this Agreement, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries.; 5(iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Further, this Agreement does not create an obligation 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. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 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 requesting Party and shall notify the competent authority of the 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the 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 Party party shall provide upon request by the requesting Party party information for the purposes referred to in Article 31. Such information shall be exchanged without regard to whether the requested Party 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 it had occurred in the territory of the requested Partyparty. The competent authority of the requesting Party 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, the requested Party party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary to provide the requesting Party 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 the requesting Partyparty, 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 Party party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party party would prefer to receive it; (d) 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 Partyparty, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party party or is in the possession of or obtainable by a person within the jurisdiction of the requested Partyparty; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Partyparty, that if the requested information was within the jurisdiction of the requesting Party party then the competent authority of the requesting Party party would be able to obtain the information under the laws of the requesting Party party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party party shall acknowledge receipt of the request to the competent authority of the requesting Party party and shall use its best endeavours to forward the requested information to the requesting Party party with the least possible reasonable delay.

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 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (iic) in the case of trusts, information on settlorssettlers, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemesschemes , unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible in specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

Exchange of Information Upon Request. 1. The competent authority of the a requested Party party shall provide upon request by the requesting Party in writing information for the purposes referred to in Article 31. 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 tax offence under the laws of the requested Party party if it had occurred in the territory of the requested Partyparty. The competent authority of the requesting Party 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 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 fact and request such additional information as may be required to enable the effective processing of the request. 3. 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, the requested party shall use the its appropriate information gathering measures it considers relevant necessary to provide the requesting Party party with the information requested, notwithstanding that the requested Party party may not need such information for its own tax purposes. 34. If specifically requested by the competent authority of the requesting Partyparty, 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. 45. Each Contracting Party shall ensure that it its competent authority, for the purposes of this Agreement, has the authority, subject to the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, trusts, foundations and other persons, and including, within the constraints of Article 3 any other 2, ownership information on all such persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors beneficiaries and beneficiariesprotectors; and in the case of foundations, information on founders, members, beneficiaries and directors or other senior officers of the foundation. 56. This Chapter Notwithstanding the preceding paragraphs, this Agreement does not create an obligation for a Party on the 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. 67. Any request for information shall be formulated with the greatest reasonable detail necessary and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature and type of the information requested requested, including a description of the information and/or specific evidence sought, and the form in which the requesting Party party would prefer to receive itthe information; (d) the tax purpose purposes 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in held by the requested Party party or is in the possession or control of or obtainable by a person within subject to the jurisdiction of the requested Partyparty; (gf) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (hg) a statement that the request conforms is in conformity with this Agreement and the laws and administrative practice practices of the requesting Partyparty, and that if the requested information was were within the jurisdiction of the requesting Party party then the competent authority of the requesting Party party would be able to obtain the information under the laws of the requesting Party party or in the normal course of administrative practice and that it is in conformity with this Chapter; andpractice; (ih) a statement that the requesting Party party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 78. The competent authority of the requested Party party shall acknowledge receipt of the request to the competent authority of the requesting Party party and shall use its best endeavours to forward the requested information as promptly as possible to the competent authority of the requesting Party with the least possible delayparty.

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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 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 requesting Party and shall notify the competent authority of the 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the 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 Party party shall provide upon request in writing by the requesting Party party information for the purposes referred to in Article 31. 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 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.it 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, the requested Party party shall use the take all relevant information gathering measures it considers relevant to provide the requesting Party 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 the requesting Partyparty, 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 Party party shall ensure that it its competent authority, for the purposes of this Agreement, has the authority, subject to the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter does not create an obligation for a Party The competent authority of the requesting party shall provide the following information to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request the competent authority of the requested party when making a.request for information shall be formulated with under this Agreement in order to demonstrate the greatest detail necessary and shall specify in writing;relevance of the information sought to the request: (a) the name of the authority seeking the information or conducting the investigation or proceeding to which the request relates; (b) the identity of the person taxpayer under examination or investigation; (b) the period for which the information is requested; (c) the nature and type of the information requested and requested, including a description of the form in which the requesting Party would prefer to receive itspecific evidence, information or other assistance sought; (d) the tax purpose purposes for which the information is sought; (e) the reasons for believing that the information requested is foreseeably relevant to tax administration and enforcement period of the requesting Party, time with respect to which the person identified in subparagraph (a) of this paragraphinformation is requested; (f) reasonable grounds for believing that the information requested is present in the territory of the requested Party party or is in the possession or control of or obtainable by a person within subject to the jurisdiction of the requested Partyparty and may be relevant to the tax purposes of the request; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement declaration that the request conforms with to the laws law and administrative practice of the requesting Partyparty and would be obtainable by the requesting party under its laws in similar circumstances, that if both for its own tax purposes and in response to a valid request from the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information party under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficultyAgreement. 76. The competent authority of the requested Party party shall acknowledge receipt of forward the request requested information as promptly as possible to the competent authority of the requesting Party 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 requesting party, and shall use its best endeavours to forward notify the competent authority of the requesting party of any deficiencies in the request within 60 days of receipt of the request; (b) if the competent authority of the requested party has been unable to obtain and provide the information requested within a reasonable period relative to the nature of the request, or if obstacles are encountered in furnishing the information, or if the competent authority of the requested party refuses to provide the information, it shall immediately inform the competent authority of the requesting Party with party to explain the least possible delayreasons 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 by the requesting Party information for the purposes referred to in Article 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) a. information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemesschemes or funds, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemesschemes or funds, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) a. the identity of the person under examination or investigation; (b) b. the period for which the information is requested; (c) c. the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) d. the tax purpose for which the information is sought; (e) e. the reasons for believing that the information requested is foreseeably forseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) f. the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) g. to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) h. a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) i. a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 it had such conduct 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 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, the requested Party shall use the all relevant information gathering measures it considers relevant necessary 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, 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 it has the authority, subject to in accordance with the terms of Article 3this agreement, to obtain and provide, through its competent authority and authority, upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, collective investment funds or schemes, trusts, foundations, “Anstalten” and other persons, and including, within the constraints of Article 3 any other 2, ownership information on all such persons in an ownership chain, including ; (c) in the case of collective investment funds or schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries; 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. This Chapter Agreement does not create an obligation for a Party on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any The competent authority of the requesting Party shall provide the following information to the competent authority of the requested Party when making a request for information shall be formulated with under the greatest detail necessary and shall specify in writing;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) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of of, or is in the control of, or obtainable by by, a person within the jurisdiction of the requested Party; (gf) to the extent known, the name and address of any person believed to be in possession or in control of or able to obtain the information requestedrequested information; (hg) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (ih) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information as promptly as possible to the requesting Party with the least possible delayParty.

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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has its competent authorities, for the authoritypurposes specified in Article 1 of the Agreement, subject to have the terms of Article 3, authority to obtain and provide, through its competent authority and provide upon request: (a) : information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacitycapacity including nominees and trustees; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations, and other persons, and within the constraints of Article 3 any other including, ownership information on all such persons in an ownership chain, including ; in the case of collective investment funds or schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries. 5; in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Agreement does not create an obligation 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. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing; (a) : the identity of the person under examination or investigation; (b) ; the period for which the information is requested; (c) ; the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) ; 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 (a) of this paragraph; (f) ; the grounds for believing that the information requested is present or held in the requested Party or is in the possession of, under the control of or obtainable by a person within the jurisdiction of the requested Party; (g) ; to the extent known, the name and address of any person believed to be in possession of, in the control of or able to obtain the information requested; (h) ; a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this ChapterAgreement; and (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge forward the requested information as promptly as possible to the requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: confirm receipt of the a request in writing to the competent authority of the requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the requesting Party with of deficiencies in the least possible delayrequest, if any, within 60 days of the receipt of the request; 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 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 Party shall provide upon request by the requesting Party information for the purposes referred to in Article 31. 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 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, the requested Party shall use the all applicable information gathering measures it considers relevant necessary to provide the 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 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 Party shall ensure that it has the authority, subject to the terms of Article 31 and 2 of this Agreement, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (ib) information regarding the legal and beneficial ownership of companies, partnerships partnerships, collective investment schemes, trusts, foundations and other persons, and within the constraints of Article 3 any other including information on all persons in an ownership chain, including 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, protectors and beneficiaries.; 5(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). This Chapter Further, this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose for which the information is sought; (e) the reasons for believing that the information requested is foreseeably foreseeable relevant to tax the administration and or enforcement of the taxes of the requesting PartyParty covered under Article 3, with respect to the person identified in subparagraph (a) of this paragraph; (f) grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession or control of or able to obtain the information requested; (h) a statement that the request conforms with the laws and administrative practice of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

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 32. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 32, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries. 5. This Chapter , provided that this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay. 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 requesting Party within 30 days of the request and shall notify the competent authority of the 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 complete request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the 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 Party shall provide upon request by the requesting Party information for the purposes referred to in Article 31. 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 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, the requested Party shall use the information gathering measures it considers relevant 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors trustees and beneficiaries. 5. This Chapter Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 6. Any request for information shall be formulated with the greatest detail necessary and shall specify possible, specifying in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficulty. 7. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delay.

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 31. 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 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it has the authority, subject to the terms of Article 31, to obtain and provide, through its competent authority and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Further, this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing; (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficulty. 76. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavours to forward the requested information to the requesting Party with the least possible delayas soon as possible.

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 31. 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 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 meansmeans 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, the requested Party shall use the at its own discretion all relevant information gathering measures it considers relevant necessary to provide the 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 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 it has the authority, subject to the terms of Article 3, authority to obtain and provide, through its competent authority authorities, in accordance with the terms of this Agreement, and upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, person acting in an agency or fiduciary capacity, including nominees and trustees; (i) information regarding the legal and beneficial ownership of companies, partnerships partnerships, foundations, and other persons, and within the constraints of Article 3 any other persons in an ownership chainincluding, including in the case of collective investment funds or schemes, information on shares, units and other interests, and information on all such persons in an ownership chain; (ii) in the case of trusts, information on settlors, trustees, protectors protectors, enforcers and beneficiaries.; and 5(iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. This Chapter Agreement does not create an obligation for on a requested Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the nature of the information sought and the form in which the requesting Party would like to receive it; c) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) 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 (a) of this paragraph; (f) the grounds for believing that the information requested is present held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Party shall acknowledge forward the requested information as promptly as possible to the requesting Party with the least possible delay. To ensure a prompt response, the competent authority of the requested Party shall: a) confirm receipt of the a request in writing to the competent authority of the requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the requesting Party with of deficiencies in the least possible delayrequest, 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 complete request, including if it encounters obstacles in furnishing the information, or it refuses to furnish the information, it shall immediately inform 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 a requested Party shall provide upon request in writing by the requesting Party information for the purposes referred to in Article 31. 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 it had 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. 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 meansmeans within its own territory, except where recourse to such means income 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 the information, the requested Party shall use the all relevant information gathering measures it considers relevant necessary 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, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Party shall ensure that it its competent authority, for the purposes of this Arrangement, has the authority, subject to Article 1, and within the terms constraints of Article 32, to obtain and provide, through its competent authority and provide upon request: (a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; (i) information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other including ownership information on all such persons in an ownership chain, including in the case of collective investment schemes, information on shares, units and other interests;; and (ii) in the case of trusts, information on settlors, trustees, protectors beneficiaries and beneficiariesprotectors. 5. This Chapter Notwithstanding the preceding paragraphs, this Arrangement does not create an obligation for a Party on the Parties to obtain or provide provide: (a) ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties; or (b) information from a period falling outside of the legally required time period for retaining the information in the jurisdiction of the requested Party, but only where that information is in fact no longer kept. 6. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature and type of the information requested requested, including, where possible, a description of the specific evidence sought and the form in which the requesting Party would prefer to receive it; (d) the tax purpose purposes for which the information is sought; (e) the reasons for believing that the information requested is foreseeably relevant to tax the administration and or enforcement of the domestic laws 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 present in the territory of the requested Party or is in the possession of or obtainable by a person within subject to the jurisdiction of the requested Party; (g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested; (h) a statement that the request conforms is in conformity with this Arrangement and the laws and administrative practice practices of the requesting Party, and that if the requested information was were within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andpractice. (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 7. The competent authority of the requested Party shall acknowledge forward the requested information as promptly as possible to the competent authority of the requesting Party. To ensure a prompt response, the competent authority of the requested Party shall: (a) confirm the receipt of the a request in writing to the competent authority of the requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the requesting Party with of any deficiencies in the least possible delayrequest within 60 days of receipt of the request; and (b) 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 complete request, including if obstacles are encountered in furnishing the information, or if the competent authority of the requested Party refuses to provide the information, it shall immediately inform the competent authority of the requesting Party to explain the reasons for its inability to obtain and provide the information 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 by the requesting Requesting Party information for the purposes referred to in Article 31. Such information shall be exchanged provided without regard to whether the requested 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 it had occurred in the territory of the requested Requested Party. The competent authority of the requesting Requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other meansmeans 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, the requested Requested Party shall use the all relevant information gathering measures it considers relevant to provide the requesting 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 the requesting 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 Party shall ensure that it has the authorityits competent authorities, subject to in accordance with the terms of Article 3, this Agreement have the authority to obtain and provide, through its competent authority and provide upon request: (a) information Information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;; and (ib) information Information regarding the legal and beneficial ownership of companies, partnerships and other persons, and within the constraints of Article 3 any other persons in an ownership chain, including in the case of collective investment funds and schemes, information on shares, units and other interests; (ii) ; in the case of trusts, information on settlors, trustees, protectors and beneficiaries. 5. This Chapter ; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, provided that this Agreement does not create an obligation for a Party on the Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 65. Any request for information shall be formulated with the greatest detail necessary possible and shall specify in writing;: (a) the The identity of the person under examination or investigation;, (b) the The period for which the information is requested;, (c) the The nature of the information requested sought and the form in which the requesting Requesting Party would prefer to receive it;, (d) the The tax purpose for which the information is sought;, (e) the The reasons for believing that the information requested is foreseeably relevant to the tax administration and enforcement of the requesting tax law of the Requesting Party, with respect to the person identified in subparagraph (a) of this paragraph;, (f) grounds Grounds for believing that the information requested is present held in the requested Requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Requested Party;, (g) to To the extent known, the name and address of any person believed to be in possession of or able to obtain the information requested;requested information, (h) a A statement that the request conforms is in conformity with the laws and administrative practice practices of the requesting Requesting Party, that if the requested information was within the jurisdiction of the requesting Requesting Party then the competent authority of the requesting Requesting Party would be able to obtain the information under the laws of the requesting Requesting Party or in the normal course of administrative practice and that it is in conformity with this Chapter; andAgreement, (i) a A statement that the requesting Requesting Party has pursued all means available in its own territory to obtain the information, except where those that would give rise to disproportionate difficultydifficulties. 76. The competent authority of the requested Requested Party shall acknowledge receipt of the request to the competent authority of the requesting Requesting Party and shall use its best endeavours to forward the requested information to the requesting Requesting Party with the least possible reasonable delay.