Common use of Exchange of Information Upon Request Clause in Contracts

Exchange of Information Upon Request. 1. The Competent Authority of the Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. If the information in the possession of the Competent Authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority of an Applicant Party, the Competent Authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) Information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information regarding the ownership of companies, partnerships, trusts, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; g) grounds for believing that the information requested is held in the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; x) to the extent known, the name and address of any person believed to be in possession of the requested information; i) a statement that the request is in conformity with the law and administrative practices of the Applicant Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; j) a statement that the Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority of the Requested Party shall acknowledge receipt of a request to the Competent Authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, and shall use its best endeavours to forward the requested information to the Applicant Party with the least possible delay.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request information for the purposes referred to in Article 1. Such information infor­ mation shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct occurred in the Requested requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information infor­ mation gathering measures to provide the Applicant applicant Party with the information infor­ mation 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 competent authority of an Applicant the appli­ cant Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide pro­ vide upon request: a) Information information held by banks, other financial institutions, and any person per­ son, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) Information information regarding the legal and beneficial ownership of companiescom­ panies, partnerships, trustsfoundations, foundations “Anstalten” and other persons, includinginclud­ ing, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustposition in an ownership chain; and in the case of foundations, information on founders, members of the foundation foun­ dation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: ah) the identity period of the taxpayer under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period time with respect to which the information is requested; e) required for the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; g) grounds for believing that the information requested is held in the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; x) to the extent known, the name and address of any person believed to be in possession of the requested information; i) a statement that the request is in conformity with the law and administrative practices of the Applicant Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; j) a statement that the Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiespurposes. 6. The Competent Authority of the Requested Party shall acknowledge receipt of a request to the Competent Authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, and shall use its best endeavours to forward the requested information to the Applicant Party with the least possible delay.

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

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant Requesting Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant Requesting Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, beneficiaries and where applicable, those persons to which the trust property title is transferred at the expiration of the trustposition in an ownership chain; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Requesting Party wishes to receive the information from the Requested Party; d) the taxable period with respect to which the information is requested; ec) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; gd) grounds for believing that the information requested is held in the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; xe) to the extent known, the name and address of any person believed to be in possession of the requested information; if) a statement that the request is in conformity with the law and administrative practices of the Applicant Requesting Party, that if the requested information was within the jurisdiction of the Applicant Requesting Party then the Competent Authority competent authority of the Applicant Requesting Party would be able to obtain the information under the laws of the Applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; jg) a statement that the Applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority 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 a request in writing to the Competent Authority competent authority of the Applicant 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. 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, shall advise if there are any unexpected delays in obtaining explaining the requested informationreason for its inability, and shall use the nature of the obstacles or the reasons for its best endeavours to forward the requested information to the Applicant Party with the least possible delayrefusal.

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

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the territory of the Requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an the Applicant Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authority for the purposes specified in Article 1 of the Agreement, have has the authority to obtain and provide upon request: (a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) Information information regarding the ownership of companies, partnerships, trusts, foundations foundations, "Anstalten" and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this This Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the taxpayer person under examination or investigation; (b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to which the information is requested; e(c) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; gd) grounds for believing that the information requested is held in the territory of the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; x(e) to the extent known, the name and address of any person believed to be in possession of the requested information; i(f) a statement that the request is in conformity with the law and administrative practices of the Applicant Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority competent authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement;; and j(g) a statement that the Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority 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 a request in writing to the Competent Authority competent authority of the Applicant Party and shall notify the competent authority of the Applicant Party of deficiencies in the request, if any, within 60 days of 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 Applicant Party, shall advise if there are any unexpected delays in obtaining explaining the requested informationreason for its inability, and shall use the nature of the obstacles or the reasons for its best endeavours to forward the requested information to the Applicant Party with the least possible delayrefusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct occurred in the Requested requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it has pursued all means available to obtain the information 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 competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures necessary to provide the Applicant requesting Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the requesting Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for it has the purposes specified in authority, subject to the terms of Article 1 of the Agreement1, have the authority to obtain and provide provide, through its competent authority and upon request: a) Information information held by banks, other financial institutions, and any person including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) Information information regarding the legal and beneficial ownership of companies, partnerships, trustsfoundations, foundations and other persons, includingpersons and, within the constraints of Article 2, ownership information on all such any other persons in an ownership chain; , including: (i) in the case of companies, information on any person, connected to the company including information on directors, secretaries, shareholders and other interests; (ii) in the case of collective investment schemes, information on shares, units and other interests; (iii) in the case of trusts, information on any person connected to the trust including information on settlors, trustees trustees, protectors and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and and (iv) in the case of foundations, information on any person connected to the foundation including information on founders, members of the foundation council and beneficiaries. FurtherNotwithstanding the preceding subparagraphs, this Agreement does not create creates an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can cannot be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a Any request for information shall be formulated with the greatest detail possible detail, and shall provide the following information, specify in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to for which the information is requested; ec) 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, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; fe) the reasons for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph. “Foreseeably relevant” is intended to provide for exchange of information to the widest possible extent, within the terms of Article 1; gf) the grounds for believing that the information requested is held present in the Requested requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the Requested requested Party; xg) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested informationinformation requested; ih) a statement that the request is in conformity with the law and administrative practices of the Applicant requesting Party, that if the requested information was within the jurisdiction of the Applicant requesting Party then the Competent Authority competent authority of the Applicant requesting Party would be able to obtain the information under the laws of the Applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; ji) a statement that the Applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiesdifficulty. 6. The Competent Authority competent authority of the Requested requested Party shall acknowledge receipt of a request to the Competent Authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, and shall use its best endeavours to forward the requested information as promptly as possible to the Applicant Party requesting Party, and in accordance with the least possible delayterms specified in the Protocol to this Agreement.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant Requesting Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant Requesting Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, beneficiaries and where applicable, those persons to which the trust property title is transferred at the expiration of the trustposition in an ownership chain; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Requesting Party wishes to receive the information from the Requested Party; d) the taxable period with respect to which the information is requested; ec) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; gd) grounds for believing that the information requested is held in the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; xe) to the extent known, the name and address of any person believed to be in possession of the requested information; if) a statement that the request is in conformity with the law and administrative practices of the Applicant Requesting Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement;jurisdiction jg) a statement that the Applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority 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 a request in writing to the Competent Authority competent authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, Requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the Applicant Requesting Party with of deficiencies in the least possible delayrequest, if any, within 60 days of the receipt of the request.

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

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request information for the purposes referred to in Article 12. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct had occurred in the Requested requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means in its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures necessary to provide the Applicant requesting Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the requesting Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for it has the purposes specified in authority, subject to the terms of Article 1 2 and within the constraints of the AgreementArticle 3, have the authority to obtain and provide through its competent authority upon request: a) Information information held by banks, other financial institutions, institutions and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information i) information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations partnerships and other persons, including, within the constraints of Article 2, including ownership information on all such persons in an ownership chain; ; ii) in the case of collective investment funds or schemes, information on shares, units and other interests; iii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and ; iv) in the case of foundations, information on founders, members of the foundation council and beneficiaries. FurtherNotwithstanding the provisions of subparagraph b) of this paragraph, this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a Any request for information shall be formulated with the greatest possible detail, as much detail as is available and shall provide the following information, in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestspecify: a) the identity of the taxpayer person under examination or investigation; b) the identity of period for which the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraphsought; c) a statement the nature of the information sought including its nature requested and the form in which the Applicant requesting Party wishes would prefer to receive the information from the Requested Partyit; d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; fe) the reasons for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; gf) grounds for believing that the information requested is held present in the Requested requested Party or is in the possession of or control of is obtainable by a person within the jurisdiction of the Requested requested Party; xg) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested information; ih) a statement that the request is in conformity with the law laws and administrative practices practice of the Applicant requesting Party, that if the requested information was within the jurisdiction of the Applicant requesting Party then the Competent Authority competent authority of the Applicant requesting Party would be able to obtain the information under the laws of the Applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; ji) a statement that the Applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested requested Party shall acknowledge the receipt of a the request to the Competent Authority competent authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, requesting Party and shall use its best endeavours to forward the requested information to the Applicant requesting Party with the least possible delayas soon as possible.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request in writing information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the Requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Contracting Party shall use all relevant information gathering measures to provide the Applicant Requesting Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the Requesting Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities, for the purposes specified in Article 1 of the this Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) Information i) information regarding the legal ownership and the beneficial ownership of companies, partnerships, trustscollective investment schemes, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; ; ii) in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustprotectors; and and iii) in the case of foundationsa foundation, information on the founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestParty: a) the identity of the taxpayer person under examination or investigation; b) the identity period of the person in time with respect of whom to which information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement the nature of the information sought including its nature requested and the form in which the Applicant Requesting Party wishes to receive the information from the Requested Partyit; d) the taxable period with respect to which the information is requested; e) the tax purpose purposes for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; ge) grounds for believing that the information requested is held present 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; xf) to the extent known, the name and address of any person believed to be in possession of or control of or able to obtain the requested information; ig) a statement that the request is in conformity conforms with the law and administrative practices of the Applicant Requesting Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; jh) a statement that the Applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficulties. 6. The Competent Authority To ensure a prompt response, the competent authority of the Requested Party shall acknowledge shall: a) confirm the receipt of a request in writing to the Competent Authority competent authority of the Applicant Requesting Party and shall 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 within 90 days of receipt of the request, it shall inform the Requesting Party, shall advise if there are any unexpected delays in obtaining explaining the requested information, and shall use reason for its best endeavours to forward the requested information to the Applicant Party with the least possible delayinability.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party State shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party State if such conduct occurred in the Requested PartyState. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party State is not sufficient to enable it to comply with the request for information, that Party State shall use all relevant information gathering measures to provide the Applicant Party State with the information requested, notwithstanding that the Requested Party State may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant PartyState, the Competent Authority competent authority of the Requested Party State 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 State shall ensure that its Competent Authorities competent authority for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) Information information regarding the ownership of companies, partnerships, trusts, foundations foundations, "Anstalten" and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Party shall formulate a request for information with the greatest possible detail, and State shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party State when making a request for information under the this Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the taxpayer person under examination or investigation; (b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party State wishes to receive the information from the Requested PartyState; d) the taxable period with respect to which the information is requested; e(c) the tax purpose for which the information is sought, including:; i(d) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; g) grounds for believing that the information requested is held in the Requested Party State or is in the possession or control of a person within the jurisdiction of the Requested PartyState; x(e) to the extent known, the name and address of any person believed to be in possession of the requested information; i(f) a statement that the request is in conformity with the law and administrative practices of the Applicant PartyState, that if the requested information was within the jurisdiction of the Applicant Party State then the Competent Authority competent authority of the Applicant Party State would be able to obtain the information under the laws of the Applicant Party State or in the normal course of administrative practice and that it the information request is in conformity with this Agreement;; and j(g) a statement that the Applicant Party State has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested Party State shall acknowledge forward the requested information as promptly as possible to the Applicant State. To ensure a prompt response, the competent authority of the Requested State shall: (a) confirm receipt of a request in writing to the Competent Authority competent authority of the Applicant PartyState and shall notify the competent authority of the Applicant State of deficiencies in the request, shall advise if there are any unexpected delays any, within 60 days of the receipt of the request; and (b) if the competent authority of the Requested State has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in obtaining furnishing the requested information or it refuses to furnish the information, and it shall use its best endeavours to forward the requested information to immediately inform the Applicant Party with State, explaining the least possible delayreason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct had occurred in the Requested 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 competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures necessary to provide the Applicant requesting Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the requesting Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for the purposes specified in Article 1 of the Agreement, have it has the authority subject to the terms of this Agreement to obtain and provide through its competent authority upon request: (a) Information information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) Information information regarding the ownership of companies, partnerships, trusts, foundations and other persons, including, within the constraints of Article 2, : (i) ownership information on all such persons in an ownership chain; ; (ii) in the case of collective investment funds or schemes, information on shares, units and other interests; (iii) in the case of trusts, information on settlors, trustees trustees, protectors and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and and (iv) in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, ; provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a Any request for information shall be formulated with the greatest detail possible detail, and shall provide the following information, specify in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: (a) the identity of the taxpayer person under examination or investigation; (b) the identity of period for which the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraphsought; (c) a statement the nature of the information sought including its nature requested and the form in which the Applicant requesting Party wishes would prefer to receive the information from the Requested Partyit; (d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f(e) the reasons for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; g(f) grounds for believing that the information requested is held present in the Requested territory of the requested Party or is in the possession of or control of is obtainable by a person within the jurisdiction of the Requested requested Party; x(g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested informationinformation requested; i(h) a statement that the request is in conformity with the law laws and administrative practices of the Applicant requesting Party, that if the requested information was within the jurisdiction of the Applicant requesting Party then the Competent Authority competent authority of the Applicant requesting Party would be able to obtain the information under the laws of the Applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; j(i) a statement that the Applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested 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 a request in writing to the Competent Authority competent authority of the Applicant 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, shall advise if there are any unexpected delays in obtaining explaining the requested informationreason for its inability, and shall use the nature of the obstacles or the reasons for its best endeavours to forward the requested information to the Applicant Party with the least possible delayrefusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct it had occurred in the Requested 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 competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant appropriate information gathering measures to provide the Applicant requesting Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the requesting Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Notwithstanding any contrary provisions in its domestic laws, each Party shall ensure that its Competent Authorities for have the purposes specified in Article authority, subject to the terms of Articles 1 and 2 of the this Agreement, have the authority to obtain and provide upon requestto provide: a) Information information held by banks, other financial institutions, trusts, foundations and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) Information information regarding the ownership of companies, partnerships, collective investment schemes, trusts, foundations and other persons, including, within the constraints of Article 2, ownership including information on all such persons in an ownership chain; , and (i) in the case of collective investment schemes, information on shares, units and other interests; (ii) in the case of trusts, information on settlors, trustees trustees, protectors, and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and ; (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further; 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): Provided that this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority A Contracting Party may request information from the other Party even if that requesting Party would not be able to obtain such information for its own purposes under its laws or in the normal course of its administrative practice if the Applicant Party shall formulate a requested information was within its jurisdiction. 6. Any request for information shall be formulated with the greatest possible detail, details and shall provide the following information, specify in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to for which the information is requested; ec) 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, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; fe) the reasons for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and or enforcement of the taxes of the requesting Party covered under Article 3, with respect to the a person identified in subparagraph (a) of this paragraph; gf) grounds for believing that the information requested is held present in the Requested requested Party or is in the possession of or control of obtainable by a person within the jurisdiction of the Requested requested Party; xg) to the extent known, the name and address of any person believed to be in possession of of, or able to obtain the requested information; ih) a statement that the request is in conformity with the law and administrative practices of the Applicant Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; ji) a statement that the Applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficultiesdifficulty. 67. The Competent Authority competent authority of the Requested requested Party shall acknowledge receipt of a the request to the Competent Authority competent authority of the Applicant requesting Party, shall advise if there are any unexpected delays in obtaining the requested information, information and shall use its best endeavours to forward the requested information to the Applicant requesting Party with the least possible reasonable delay.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested a requested Party shall provide upon request in writing by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct it occurred in the Requested territory of the requested Party. 2. If the information in received by the possession competent authority of the Competent Authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, it shall advise the competent authority of the requesting Party of that fact and request such additional information as may be required to enable the effective processing of the request. 2. If the information in possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for the information, the requested Party shall use all relevant information gathering measures to provide the Applicant requesting Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the requesting Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) Information information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; and in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: (i) ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties; (ii) information which is older than a legally required time period for retaining that information in the jurisdiction of the requested Party and where that information is in fact no longer kept. 56. The Competent Authority competent authority of the Applicant requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested requested Party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to for which the information is requested; ec) the nature and type of the information requested, including a description of the specific information sought and the form in which the requesting Party would prefer to receive the information; d) the tax purpose purposes for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) sought and the reasons for considering believing that the information requested is foreseeably relevant to the Applicant administration or enforcement of the domestic laws of the requesting Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; ge) reasonable grounds for believing that the information requested is held present in the Requested territory of the requested Party or is in the possession or control of a person within subject to the jurisdiction of the Requested requested Party; xf) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; ig) a statement that the request is in conformity with this Agreement and the law laws and administrative practices of the Applicant requesting Party, and that if the requested information was were within the jurisdiction of the Applicant requesting Party then the Competent Authority competent authority of the Applicant requesting Party would be able to obtain the information under the laws of the Applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; jh) a statement that the Applicant Party requesting territory has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The Competent Authority competent authority of the Requested 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 a request in writing to the Competent Authority competent authority of the Applicant Party, requesting Party and shall advise 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 there are any unexpected delays in obtaining 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, and shall use its best endeavours to forward or if the competent authority of the requested information Party refuses to provide the Applicant information, it shall immediately inform the competent authority of the requesting Party with to explain the least possible delayreasons for its inability or the obstacles or its refusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request information infor- mation for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct occurred in the Requested requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant applicant Party with the information infor- mation 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 competent authority of an Applicant applicant Party, the Competent Authority com- petent 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 aut- henticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the ownership of companies, partnerships, trusts, foundations foun- dations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council cou- ncil and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant applicant Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, infor- mation to the Competent Authority competent authority of the Requested requested Party when making a request for information informa- tion under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant applicant Party wishes to receive the information from the Requested requested Party; d) the taxable period with respect to which the information is requested; ec) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; gd) grounds for believing that the information requested is held in the Requested requested Party or is in the possession or control of a person within the jurisdiction of the Requested requested Party; xe) to the extent known, the name and address of any person believed to be in possession of the requested information; if) a statement that the request is in conformity with the law and administrative practices of the Applicant applicant Party, that if the requested information was within the jurisdiction of the Applicant applicant Party then the Competent Authority competent authority of the Applicant applicant Party would be able to obtain the information under the laws of the Applicant applicant Party or in the normal course of administrative practice and that it is in conformity con- formity with this Agreement; jg) a statement that the Applicant applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate dis- proportionate difficulties. 6. The Competent Authority competent authority of the Requested requested Party shall acknowledge forward the requested infor- mation as promptly as possible to the applicant Party. To ensure a prompt response, the com- petent authority of the requested Party shall: a) Confirm receipt of a request in writing to the Competent Authority competent authority of the Applicant app- licant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, shall advise if there are any unexpected delays in obtaining explaining the requested informationreason for its inability, and shall use the nature of the obstacles or the reasons for its best endeavours to forward the requested information to the Applicant Party with the least possible delayrefusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged 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 requested party if such conduct it had occurred in the Requested 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 competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant applicant Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the applicant Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the ownership of companies, partnerships, trusts, foundations foundations, “Antstalten” and other persons, including, within the constraints of Article 2, ownership information on all ail such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a Any request for information shall be formulated with the greatest detail possible detail, and shall provide the following information, specify in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant applicant Party wishes to receive the information from the Requested requested Party; d) the taxable period with respect to which the information is requested; ec) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; gd) grounds for believing that the information requested is held in the Requested requested Party or is in the possession or control of a person within the jurisdiction of the Requested requested Party; xe) to the extent known, the name and address of any person believed to be in possession of the requested information; if) a statement that the request is in conformity with the law and administrative practices of the Applicant applicant Party, that if the requested information was within the jurisdiction of the Applicant applicant Party then the Competent Authority competent authority of the Applicant applicant Party would be able to obtain the information under the laws of the Applicant applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; jg) a statement that the Applicant applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested 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 a request in writing to the Competent Authority competent authority of the Applicant applicant Party and shall notify the competent authority of the applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request. b) If the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the applicant Party, shall advise if there are any unexpected delays in obtaining explaining the requested informationreason for its inability, and shall use the nature of the obstacles or the reasons for its best endeavours to forward the requested information to the Applicant Party with the least possible delayrefusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct had occurred in the Requested requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means within its own territory, except where recourse to such means would give rise to disproportionate difficulty. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use at its own discretion all relevant information gathering measures necessary to provide the Applicant requesting Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the requesting Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for it has the purposes specified in authority subject to the terms of Article 1 and within the constraints of the Agreement, have the authority Article 2 to obtain and provide through its competent authority upon request: (a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b(i) Information information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations and other persons, including, within the constraints of Article 2, including ownership information on all such persons in an ownership chain; ; (ii) in the case of collective investment funds or schemes, information on shares, units and other interests; (iii) in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and ; (iv) in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, ; provided that this Agreement does not create an obligation on the Contracting Parties for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a Any request for information shall be formulated with the greatest detail possible detail, and shall provide the following information, specify in writing, to the Competent Authority of the Requested Party when making writing as a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestminimum: (a) the identity of the taxpayer person under examination or investigation; (b) the identity of period for which the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraphsought; (c) a statement the nature of the information sought including its nature requested and the form in which the Applicant requesting Party wishes would prefer to receive the information from the Requested Partyit; (d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f(e) the reasons for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; g(f) grounds for believing that the information requested is held present in the Requested requested Party or is in the possession of or control of is obtainable by a person within the jurisdiction of the Requested requested Party; x(g) to the extent known, the name and address of any person believed to be in possession of or able to obtain the requested information; i(h) a statement that the request is in conformity with the law laws and administrative practices of the Applicant requesting Party, that if the requested information was within the jurisdiction of the Applicant requesting Party then the Competent Authority competent authority of the Applicant requesting Party would be able to obtain the information under the laws of the Applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; j(i) a statement that the Applicant requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested requested Party shall acknowledge receipt of a the request to the Competent Authority competent authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, requesting Party and shall use its best endeavours to forward the requested information to the Applicant requesting Party with the least possible delay.

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

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested a requested Party shall provide upon request in writing by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested requested Party if such conduct it occurred in the Requested territory of the requested Party. 2. If the information in received by the possession competent authority of the Competent Authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, it shall advise the competent authority of the requesting Party of that fact and request such additional information as may be required to enable the effective processing of the request. 2. If the information in possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for the information, the requested Party shall use all relevant information gathering measures to provide the Applicant requesting Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the requesting Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) Information information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations foundations, “Anstalten” and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; and in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: (i) ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties; (ii) information which is older than a legally required time period for retaining that information in the jurisdiction of the requested Party and where that information is in fact no longer kept. 56. The Competent Authority competent authority of the Applicant requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested requested Party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to for which the information is requested; ec) the nature and type of the information requested, including a description of the d) the tax purpose purposes for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) sought and the reasons for considering believing that the information requested is foreseeably relevant to the Applicant administration or enforcement of the domestic laws of the requesting Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; ge) reasonable grounds for believing that the information requested is held present in the Requested territory of the requested Party or is in the possession or control of a person within subject to the jurisdiction of the Requested requested Party; xf) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; ig) a statement that the request is in conformity with this Agreement and the law laws and administrative practices of the Applicant requesting Party, and that if the requested information was were within the jurisdiction of the Applicant requesting Party then the Competent Authority competent authority of the Applicant requesting Party would be able to obtain the information under the laws of the Applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; jh) a statement that the Applicant Party requesting territory has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The Competent Authority competent authority of the Requested 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 a request in writing to the Competent Authority competent authority of the Applicant Party, requesting Party and shall advise 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 there are any unexpected delays in obtaining 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, and shall use its best endeavours to forward or if the competent authority of the requested information Party refuses to provide the Applicant information, it shall immediately inform the competent authority of the requesting Party with to explain the least possible delayreasons for its inability or the obstacles or its refusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party requested party shall provide upon request by the requesting party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party requested party if such conduct it had occurred in the Requested Partyterritory of the requested party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party requested party is not sufficient to enable it to comply with the request for information, that Party the requested party shall use take all relevant information gathering measures to provide the Applicant Party requesting party with the information requested, notwithstanding that the Requested Party requested party may not not, at that time, need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant Partythe requesting party, the Competent Authority competent authority of the Requested Party 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 party shall ensure that its Competent Authorities competent authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: (a) Information information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; (b) Information information regarding the beneficial ownership of companies, partnerships, trusts, foundations partnerships and other persons, includingincluding in the case of collective investment funds, within the constraints of Article 2, ownership information on all such persons in an ownership chainshares, units and other interests; and in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Party shall formulate a request for information with the greatest possible detail, and requesting party shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party requested party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information sought to the request: (a) the identity of the taxpayer under examination or investigation; (b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement nature 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 taxable period with respect to which the information is requested; e(c) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f(d) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; g) reasonable grounds for believing that the information requested is held present in the Requested Party territory of the requested party or is in the possession or control of a person within subject to the jurisdiction of the Requested Partyrequested party; x(e) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; i(f) a statement declaration that the request is in conformity with conforms to the law and administrative practices practice of the Applicant Partyrequesting party 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 Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information party under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; j) a statement that the Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested Party 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 receipt of a request in writing to the Competent Authority competent authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested informationrequesting 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 Applicant Party with nature of the least possible delayrequest, 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 to explain the reasons for its inability or the obstacles or its refusal.

Exchange of Information Upon Request. 1. The Competent Authority of the Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. If the information in the possession of the Competent Authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority of an Applicant Party, the Competent Authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) Information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information regarding the ownership of companies, partnerships, trusts, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; g) grounds for believing that the information requested is held in the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; xh) to the extent known, the name and address of any person believed to be in possession of the requested information; i) a statement that the request is in conformity with the law and administrative practices of the Applicant Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; j) a statement that the Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority of the Requested Party shall acknowledge receipt of a request to the Competent Authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, and shall use its best endeavours to forward the requested information to the Applicant Party with the least possible delay.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the 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 such conduct occurred in the Requested requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant requesting Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the requesting Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person person, acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the ownership of companies, partnerships, collective investment funds or schemes, trusts, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of collective investment funds or schemes, information on shares, units and other interests; in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, information in writing, writing to the Competent Authority competent authority of the Requested requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information sought to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom taxable period for which information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant applicant Party wishes to receive the information from the Requested requested Party; d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; fe) the reasons grounds for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement of the domestic tax laws of the applicant Party with respect regard to the person identified specified in subparagraph (a) of this paragraph); gf) grounds for believing that the information requested is held present in the Requested requested Party or is in the possession or control of a person within the jurisdiction of the Requested requested Party; xg) to the extent known, the name and address of any person believed to be in possession or control of the requested information; ih) a statement that the request is in conformity with the law laws and administrative practices of the Applicant requesting Party, that if the requested information was within the jurisdiction of the Applicant requesting Party then the Competent Authority competent authority of the Applicant requesting Party would be able to obtain the information under the laws of the Applicant requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; ji) a statement that the Applicant requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested 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 a request in writing to the Competent Authority competent authority of the Applicant 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 request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the requesting Party, shall advise if there are any unexpected delays in obtaining explaining the requested informationreason for its inability, and shall use the nature of the obstacles or the reasons for its best endeavours to forward the requested information to the Applicant Party with the least possible delayrefusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct would have occurred in the Requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the ownership of companies, partnerships, trusts, foundations foundations, and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to which the information is requested; ec) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; gd) grounds for believing that the information requested is held in the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; xe) to the extent known, the name and address of any person believed to be in possession of the requested information; if) a statement that the request is in conformity with the law and administrative practices of the Applicant Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority competent authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; jg) a statement that the Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority 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 a request in writing to the Competent Authority competent authority of the Applicant Party and shall notify the competent authority of the Applicant Party of deficiencies in the request, if any, within 60 days of the receipt of the request; b) If the competent authority of the Requested Party has been unable to obtain and provide the information within 90 days of receipt of the request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal. 7. Requests shall advise if there are any unexpected delays be submitted in obtaining writing in the requested information, official language of the country receiving such request – in the case of Argentina: Spanish language or in the case of the Cayman Islands: English language – and shall use its best endeavours to forward the requested information to the Applicant Party with the least possible delaymay be made by electronic means.

Exchange of Information Upon Request. 1. The Competent Authority 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 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct it occurred in the territory of the Requested Party. 2. If the information in received by the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, it shall, in accordance with the terms provided in paragraph 7 a), advise the competent authority of the Requesting Party of that fact and request such additional information as may be required to enable the effective processing of the request. 2. If the information in possession of the competent authority of the Requested Party is not sufficient to enable it to comply with the request for the information, the Requested Party shall use all relevant information gathering measures to provide the Applicant Requesting Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the Requesting Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: a) Information a. information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) Information b. information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations partnerships and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; and in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries, and equivalent information in the case of entities that are neither trusts nor foundations. 5. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: a. ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties; b. information relating to a period more than six years prior to the tax period under consideration; c. information in the possession or control of a person other than the taxpayer that does not directly relate to the taxpayer. 56. The Competent Authority competent authority of the Applicant Requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: a) a. the identity of the taxpayer person under examination or investigation; b) b. the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to for which the information is requested; e) c. the nature and type of the information requested, including a description of the specific evidence sought and the form in which the Requesting Party would prefer to receive the information; d. the tax purpose purposes for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) sought and the reasons for considering that why the information requested is foreseeably relevant to the Applicant administration or enforcement of the domestic laws of the Requesting Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; g) e. grounds for believing that the information requested is held present in the territory of the Requested Party or is in the possession or control of a person within subject to the jurisdiction of the Requested Party; x) f. to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; i) g. a statement declaration that the request is in conformity with this Agreement and the law laws and administrative practices of the Applicant Requesting Party, and that if the requested information was were within the jurisdiction of the Applicant Requesting Party then the Competent Authority competent authority of the Applicant Requesting Party would be able to obtain the information under the laws of the Applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; j) h. a statement that the Applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The Competent Authority 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: a. the competent authority of the Requested Party shall confirm the receipt of a request in writing to the Competent Authority competent authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, Requesting Party and shall use its best endeavours to forward notify the requested information to competent authority of the Applicant Requesting Party with of any deficiencies in the least possible delay.request within 60 days of receipt of the request; and

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide information upon request information by the competent authority of the applicant Party for the purposes referred to in Article 11 (Object and Scope of this Agreement). 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 requested Party if such conduct occurred in the Requested requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that the requested Party shall use all relevant information gathering measures to provide the Applicant applicant Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. Privileges under the laws and practices of the applicant 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 applicant Party. 3. If specifically requested by the Competent Authority competent authority of an Applicant the applicant Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authority, for the purposes specified in Article 1 (Object and Scope of the this Agreement) of this Agreement, have has the authority to obtain and provide upon request: (a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees;; and (b) Information information regarding the ownership of companies, partnerships, trusts, foundations foundations, “Anstalten” and other persons, including, within the constraints of Article 22 (Jurisdiction), ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. FurtherNotwithstanding subparagraph 4(b), this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficultiesdifficulties to the requested Party. 5. The Competent Authority competent authority of the Applicant applicant Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested requested Party when making a request for information under this Agreement, with the Agreement to demonstrate the foreseeable relevance greatest degree of the information to the requestspecificity possible: (a) the identity of the taxpayer person or ascertainable group or category of persons under examination or investigation; (b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought sought, including its nature and the form in which the Applicant applicant Party wishes to receive the information from the Requested requested Party; d(c) the taxable period of time with respect to which the information is requested; e(d) the tax purpose for which the information is sought, including: i) the provision matter under the Applicant applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f(e) the reasons grounds for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and or enforcement of the applicant Party with respect to the person or group or category of persons identified in subparagraph (a) of this paragraph5(a); g(f) grounds for believing that the information requested is held in the Requested requested Party or is in the possession or control of a person within the jurisdiction of the Requested requested Party; x(g) to the extent known, the name and address of any person believed to be in possession or control of the requested information; i(h) a statement that the request is in conformity with the law and administrative practices of the Applicant applicant Party, that if the requested information was within the jurisdiction of the Applicant applicant Party then the Competent Authority competent authority of the Applicant applicant Party would be able to obtain the information under the laws of the Applicant applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement;; and j(i) a statement that the Applicant applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested requested Party shall acknowledge receipt of a request to the Competent Authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, and shall use its best endeavours intends to forward the requested information as promptly as possible to the Applicant applicant Party. To ensure a prompt response, the competent authority of the requested Party with intends to: a) confirm receipt of a request in writing to the least possible delaycompetent authority of the applicant Party and 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 information, promptly inform the applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide provide, upon request of the applicant Party, information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the 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 such conduct occurred in the Requested territory of the requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant applicant Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the applicant Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its the domestic lawslaws of the requested Party, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for the purposes specified in Article 1 of the Agreement, have competent authority has the authority to obtain and provide upon request, in accordance with the terms of this Agreement: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the ownership of companies, partnerships, trusts, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on for the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a Any request for information shall be formulated in writing with the greatest detail possible detail, and shall provide in all cases include the following information, in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestfollowing: a) the identity of the taxpayer person under examination or investigation; b) the identity of taxable period for which the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraphsought; c) a statement description of the information sought including its nature and the form in which the Applicant applicant Party wishes to receive the information from the Requested requested Party; d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including:; ie) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons grounds for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement of the domestic tax laws of the applicant Party with respect regard to the person identified specified in subparagraph (a) of this paragraph); gf) the grounds for believing that the information requested is held in the Requested territory of the requested Party or is in the possession or control of a person within the jurisdiction of the Requested requested Party; xg) to the extent known, the name and address of any person believed to be in possession of the requested information; ih) a statement that the request is in conformity with the law and administrative practices of the Applicant applicant Party, that if the requested information was within the jurisdiction of the Applicant applicant Party then the Competent Authority competent authority of the Applicant applicant Party would be able to obtain the information under the laws of the Applicant applicant Party or in the normal course of its administrative practice and that it is in conformity with this Agreement;; and ji) a statement that the Applicant applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested requested Party shall acknowledge receipt of a the request to the Competent Authority competent authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, applicant Party and shall use its best endeavours to forward the requested information to the Applicant applicant Party with the least possible delaywithin a reasonable time.

Exchange of Information Upon Request. 1. The Competent Authority 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 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct it occurred in the Requested jurisdiction of the requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that the Requested Party shall use all relevant information gathering measures to provide the Applicant 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 competent authority of an Applicant the Requesting Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authority, for the purposes specified in Article 1 of the this Agreement, have has the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b) Information information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations partnerships and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in ownership 5. Notwithstanding the case of trusts, information on settlors, trustees and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Furtherpreceding paragraphs, this Agreement does not create an obligation on the Contracting Parties to obtain or provide provide: a) ownership information with respect to publicly traded companies or public collective investment funds or schemes schemes, unless such information can be obtained without giving rise to disproportionate difficulties; b) information relating to a period more than six years prior to the tax period under consideration; c) information in the possession or control of a person other than the taxpayer that does not directly relate to the taxpayer. 56. The Competent Authority competent authority of the Applicant Requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement in order to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period with respect to for which the information is requested; ec) the nature and type of the information requested, including a description of any specific evidence sought and the form in which the Requesting Party would prefer to receive the information; d) the tax purpose for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) sought and the reasons for considering believing that the information requested is foreseeably relevant to the Applicant administration or enforcement of the domestic laws of the Requesting Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; ge) grounds for believing that the information requested is held present in the jurisdiction of the Requested Party or is in the possession or control of a person within subject to the jurisdiction of the Requested Party; xf) to the extent known, the name and address of any person believed to be in possession or control of the requested informationinformation requested; ig) a statement that the request is in conformity with this Agreement and the law and administrative practices of the Applicant Party, Requesting Party and that if the requested information was were within the jurisdiction of the Applicant Requesting Party then the Competent Authority competent authority of the Applicant Requesting Party would be able to obtain the information under the laws of the Applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreementpractice; jh) a statement that the Applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 67. The Competent Authority 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 receipt of a request in writing to the Competent Authority competent authority of the Applicant PartyRequesting Party and shall notify the competent authority of the Requesting Party of any deficiencies in the request 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, shall advise if there obstacles are any unexpected delays encountered in obtaining furnishing the requested information or if the competent authority of the Requested party refuses to provide the information, it shall immediately inform the Requesting Party in writing, explaining the reason for its inability to obtain and shall use provide the information or the reasons for its best endeavours refusal. 8. For the purposes of this Agreement, the Contracting Parties may enter into a Memorandum of Understanding to forward deal with any procedural matters they consider necessary for the requested processing of requests for the provision under this Agreement of information to the Applicant Party with the least possible delayon tax matters and any other matters connected therewith.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request in writing information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the Requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Contracting Party shall use all relevant information gathering measures to provide the Applicant Requesting Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the Requesting Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities, for the purposes specified in Article 1 of the this Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) Information information regarding the legal ownership and the beneficial ownership of companies, partnerships, trustscollective investment schemes, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; ; (ii) in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustprotectors; and and (iii) in the case of foundationsa foundation, information on the founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestParty: a) the identity of the taxpayer person under examination or investigation; b) the identity period of the person in time with respect of whom to which information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement the nature of the information sought including its nature requested and the form in which the Applicant Requesting Party wishes to receive the information from the Requested Partyit; d) the taxable period with respect to which the information is requested; e) the tax purpose purposes for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; ge) grounds for believing that the information requested is held present 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; xf) to the extent known, the name and address of any person believed to be in possession of or in control of or able to obtain the requested information; ig) a statement that the request is in conformity conforms with the law and administrative practices of the Applicant Requesting Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; jh) a statement that the Applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficulties. 6. The Competent Authority To ensure a prompt response, the competent authority of the Requested Party shall acknowledge shall: a) confirm the receipt of a request in writing to the Competent Authority competent authority of the Applicant Requesting Party and shall 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 within 90 days of receipt of the request, it shall inform the Requesting Party, shall advise if there are any unexpected delays in obtaining explaining the requested information, and shall use reason for its best endeavours to forward the requested information to the Applicant Party with the least possible delayinability.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request in writing information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the Requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Contracting Party shall use all relevant information gathering measures to provide the Applicant Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes.information 3. If specifically requested by the Competent Authority competent authority of an Applicant the Requesting Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities, for the purposes specified in Article 1 of the this Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person person, including nominees and trustees, acting in an agency or fiduciary capacity including nominees and trusteescapacity; b(i) Information information regarding the legal ownership and the beneficial ownership of companies, partnerships, trustscollective investment schemes, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; ; (ii) in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustprotectors; and and (iii) in the case of foundationsa foundation, information on the founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestParty: a) the identity of the taxpayer person under examination or investigation; b) the identity period of the person in time with respect of whom to which information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement the nature of the information sought including its nature requested and the form in which the Applicant Requesting Party wishes to receive the information from the Requested Partyit; d) the taxable period with respect to which the information is requested; e) the tax purpose purposes for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; ge) grounds for believing that the information requested is held present 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; xf) to the extent known, the name and address of any person believed to be in possession of or in control of or able to obtain the requested information; ig) a statement that the request is in conformity conforms with the law and administrative practices of the Applicant Requesting Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of administrative practice and that it is in conformity with this Agreement; jh) a statement that the Applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficulties. 6. The Competent Authority To ensure a prompt response, the competent authority of the Requested Party shall acknowledge shall: a) confirm the receipt of a request in writing to the Competent Authority competent authority of the Applicant Requesting Party and shall 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 within 90 days of receipt of the request, it shall inform the Requesting Party, shall advise if there are any unexpected delays in obtaining explaining the requested information, and shall use reason for its best endeavours to forward the requested information to the Applicant Party with the least possible delayinability.

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

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request in writing information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the Requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party.. If the information received by the competent authority of the Requested Party is not sufficient to enable it to comply 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Contracting Party shall use all relevant information gathering measures to provide the Applicant Requesting Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the Requesting Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities, for the purposes specified in Article 1 of the this Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the legal ownership and beneficial ownership of companies, partnerships, trusts, foundations foundations, collective investment funds, and other persons, persons including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees trustees, beneficiaries and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trustprotectors; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on ; provided that in the Contracting Parties to obtain or provide ownership information with respect to case of publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Requesting Party shall formulate a request for information with the greatest possible detail, and shall provide the following information, in writing, information to the Competent Authority competent authority of the Requested Party when making a request for information under the this Agreement in order to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of period for which the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the specific evidence, information or other assistance sought including its nature and the form in which the Applicant Requesting Party wishes to receive the information from the Requested Party; d) the taxable period with respect to which the information is requested; e) the tax purpose purposes for which the information is sought, including: i) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; fe) the reasons for considering that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; g) reasonable grounds for believing that the information requested is held in by the authorities of the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; xf) to the extent known, the name and address of any person believed to be in possession or control of the requested information; ig) a statement declaration that the request is in conformity with the law and administrative practices of the Applicant Requesting Party, that if the requested information was within the jurisdiction of the Applicant Requesting Party then the Competent Authority competent authority of the Applicant Requesting Party would be able to obtain the information under the laws of the Applicant Requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement; jh) a statement that the Applicant Requesting Party has pursued all means available in its own territory to obtain the information, except those where that would give rise to disproportionate difficulties. 6. The Competent Authority 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 the receipt of a request in writing to the Competent Authority competent authority of the Applicant Requesting Party and shall 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 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, shall advise if there are any unexpected delays in obtaining explaining the requested informationreason for its inability, and shall use the nature of the obstacles or the reasons for its best endeavours to forward the requested information to the Applicant Party with the least possible delayrefusal.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested Party shall provide upon request information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the conduct being investigated would constitute a crime under the laws of the Requested Party if such conduct occurred in the Requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant Party with the information requested, notwithstanding that the Requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant Party, the Competent Authority competent authority of the Requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities competent authorities for the purposes specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b(i) Information information regarding the legal and beneficial ownership of companies, partnerships, trusts, foundations foundations, and other persons, including, within the constraints of Article 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 and beneficiaries, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and and (iii) in the case of foundations, information on founders, members of the foundation council and beneficiaries. FurtherNotwithstanding the preceding paragraphs, this Agreement does not create creates an obligation on the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can cannot be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority competent authority of the Applicant Party shall formulate a request for information with the greatest possible detail, detail and shall provide the following information, information in writing, writing to the Competent Authority competent authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer under examination or investigation; b) the identity of the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraph; c) a statement of the information sought including its nature and the form in which the Applicant Party wishes to receive the information from the Requested Party; d) the taxable period of time with respect to which the information is requested; e) the tax purpose for which the information is sought, sought including: (i) the provision citation of the legal authority under the Applicant Party’s tax or other law with respect to which the information is sought; and; (ii) whether the matter relates to is a criminal tax offence;matter; and f(iii) the reasons for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement with respect to the person identified in subparagraph (a) of this paragraph; gf) the grounds for believing that the information requested is held in the Requested Party or is in the possession or control of a person within the jurisdiction of the Requested Party; xg) to the extent known, the name and address of any person believed to be in possession of the requested information; ih) a statement that the request is in conformity with the law and administrative practices of the Applicant Party, that if the requested information was within the jurisdiction of the Applicant Party then the Competent Authority competent authority of the Applicant Party would be able to obtain the information under the laws of the Applicant Party or in the normal course of its administrative practice and that it the request is in conformity with this Agreement;; and ji) a statement that the Applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority 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 a request (and any subsequent corrected requests) in writing to the Competent Authority competent authority of the Applicant Party no later then fifteen working days after receipt. b) 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 any subsequent corrected requests). c) If the competent authority of the Requested Party has been unable to obtain and provide the information within 90 days of receipt of a properly constituted request, including if it encounters obstacles in furnishing the information or it refuses to furnish the information, it shall immediately inform the Applicant Party, explaining the reason for its inability, the nature of the obstacles or the reasons for its refusal. The Applicant Party shall advise if there are subsequently decide whether or not to rescind its request. If it decides not to rescind its request the Parties shall informally and directly, through Mutual Agreement or otherwise, discuss the possibilities to achieve the purpose of the request and consult with each other the manner in which to achieve that objective. d) 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. The time restrictions mentioned in this Article do not in any unexpected delays way impact on the validity and legality of information exchanged under this Agreement. 7. The competent authorities of the Contracting Parties may by mutual agreement settle the mode in obtaining the requested information, and which requests for information shall use its best endeavours to forward the requested information be submitted to the Applicant Party with the least possible delayRequested Party.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide provide, upon request of the applicant Party, information for the purposes referred to in Article Article 1. 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 requested Party if such conduct occurred in the Requested territory of the requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant applicant Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the applicant Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its the domestic lawslaws of the requested Party, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for the purposes specified in Article 1 of the Agreement, have competent authority has the authority to obtain and provide upon request, in accordance with the terms of this Agreement: a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; b) Information information regarding the ownership of companies, partnerships, trusts, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on for the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a Any request for information shall be formulated in writing with the greatest detail possible detail, and shall provide in all cases include the following information, in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the request: a) the identity of the taxpayer person under examination or investigation; b) the identity of taxable period for which the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraphsought; c) a statement description of the information sought including its nature and the form in which the Applicant applicant Party wishes to receive the information from the Requested requested Party; d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including:; ie) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons grounds for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement of the domestic tax laws of the applicant Party with respect regard to the person identified specified in subparagraph (a) of this paragraph); gf) the grounds for believing that the information requested is held in the Requested territory of the requested Party or is in the possession or control of a person within the jurisdiction of the Requested requested Party; xg) to the extent known, the name and address of any person believed to be in possession of the requested information; ih) a statement that the request is in conformity with the law and administrative practices of the Applicant applicant Party, that if the requested information was within the jurisdiction of the Applicant applicant Party then the Competent Authority competent authority of the Applicant applicant Party would be able to obtain the information under the laws of the Applicant applicant Party or in the normal course of its administrative practice and that it is in conformity with this Agreement;; and ji) a statement that the Applicant applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested requested Party shall acknowledge receipt of a the request to the Competent Authority competent authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, applicant Party and shall use its best endeavours to forward the requested information to the Applicant applicant Party with the least possible delaywithin a reasonable time.

Exchange of Information Upon Request. 1. The Competent Authority competent authority of the Requested requested Party shall provide provide, upon request of the applicant Party, information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the 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 such conduct occurred in the Requested territory of the requested Party. 2. If the information in the possession of the Competent Authority competent authority of the Requested requested Party is not sufficient to enable it to comply with the request for information, that Party shall use all relevant information gathering measures to provide the Applicant applicant Party with the information requested, notwithstanding that the Requested requested Party may not need such information for its own tax purposes. 3. If specifically requested by the Competent Authority competent authority of an Applicant the applicant Party, the Competent Authority competent authority of the Requested requested Party shall provide information under this Article, to the extent allowable under its the domestic lawslaws of the requested Party, in the form of depositions of witnesses and authenticated copies of original records. 4. Each Contracting Party shall ensure that its Competent Authorities for the purposes specified in Article 1 of the Agreement, have competent authority has the authority to obtain and provide upon request, in accordance with the terms of this Agreement: (a) Information information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and trustees; (b) Information information regarding the ownership of companies, partnerships, trusts, foundations and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in the case of trusts, information on settlors, trustees and beneficiaries; and, and where applicable, those persons to which the trust property title is transferred at the expiration of the trust; and in the case of foundations, information on founders, members of the foundation council and beneficiaries. Further, this Agreement does not create an obligation on for the Contracting Parties to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes unless such information can be obtained without giving rise to disproportionate difficulties. 5. The Competent Authority of the Applicant Party shall formulate a Any request for information shall be formulated in writing with the greatest detail possible detail, and shall provide in all cases include the following information, in writing, to the Competent Authority of the Requested Party when making a request for information under the Agreement to demonstrate the foreseeable relevance of the information to the requestfollowing: (a) the identity of the taxpayer person under examination or investigation; (b) the identity of taxable period for which the person in respect of whom information is requested, if that person is not also the taxpayer in subparagraph (a) of this paragraphsought; (c) a statement description of the information sought including its nature and the form in which the Applicant applicant Party wishes to receive the information from the Requested requested Party; (d) the taxable period with respect to which the information is requested; e) the tax purpose for which the information is sought, including:; i(e) the provision under the Applicant Party’s tax or other law with respect to which the information is sought; and ii) whether the matter relates to a tax offence; f) the reasons grounds for considering believing that the information requested is foreseeably relevant to the Applicant Party’s tax administration and enforcement of the domestic tax laws of the applicant Party with respect regard to the person identified specified in subparagraph (a) of this paragraph); g(f) the grounds for believing that the information requested is held in the Requested territory of the requested Party or is in the possession or control of a person within the jurisdiction of the Requested requested Party; x(g) to the extent known, the name and address of any person believed to be in possession of the requested information; i(h) a statement that the request is in conformity with the law and administrative practices of the Applicant applicant Party, that if the requested information was within the jurisdiction of the Applicant applicant Party then the Competent Authority competent authority of the Applicant applicant Party would be able to obtain the information under the laws of the Applicant applicant Party or in the normal course of its administrative practice and that it is in conformity with this Agreement;; and j(i) a statement that the Applicant applicant Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. 6. The Competent Authority competent authority of the Requested requested Party shall acknowledge receipt of a the request to the Competent Authority competent authority of the Applicant Party, shall advise if there are any unexpected delays in obtaining the requested information, applicant Party and shall use its best endeavours to forward the requested information to the Applicant applicant Party with the least possible delaywithin a reasonable time.