Common use of Possibility of Declining a Request Clause in Contracts

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, paragraph 4, shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assistassist where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Applicant Party has not pursued all means available in its own territory to obtain the informationjurisdiction, except where recourse to such means would give rise to disproportionate difficulty; or; (c) where the disclosure of the information requested would be contrary to the public policy of the requested Requested Party; (d) the request is directed at a person, other than the taxpayer, in respect of information that does not relate specifically to the tax affairs of the taxpayer; or (e) the Applicant Party would not be able to obtain the information (i) under its own laws for purposes of administration or enforcement of its own tax laws or (ii) in response to a valid request from the Requested Party under this Agreement. 2. This The provisions of this Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information, which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications: (a) are communications between a professional legal adviser and a client made in connection with the giving of legal advice to the client; (b) are communications between a professional legal adviser and a client, professional legal adviser acting for the client and another person, or the client and another person made in connection with or in contemplation of legal proceedings and for the purposes of such proceedings; and (c) include items enclosed with or referred to in such communications and made: (i) in connection with the giving of legal advice; or (ii) in connection with or in contemplation of legal proceedings and for the purposes of such proceedings, when the items are in the possession of a person who is entitled to possession of them. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if disputed by the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practicetaxpayer. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Applicant Party to administer or enforce a provision of the tax law of the requesting Applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Partyparty. 2. This Agreement shall not impose upon a requested Party contracting party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3. This Agreement shall not impose on a contracting party an obligation to provide information held that is subject to legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Partyparty, the competent authority of the requesting Party party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party party may decline a request for information if the information is requested by the requesting Party party to administer or enforce a provision of the tax law of the requesting Partyparty, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party party as compared with a national or citizen of the requesting Party party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties contracting parties shall be kept confidential. 2. Such information confidential and shall be disclosed only to persons or authorities (including courts and administrative bodies) officially concerned with the purposes specified in Article 1, 1 and used by such persons or authorities only for such purposes, including the determination of any appeal, or the oversight of the above. For these purposes, information may be disclosed in public court proceedings or in judicial decisionsproceedings. 32. Such The information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Partyparty. 43. Information provided to a requesting Party under this Agreement may party shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Partyparty. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client (or his admitted legal representative) and a professional legal advisor where such communications are (i) produced for the purposes of seeking or providing legal advice; or (ii) produced for the purposes of use in existing or contemplated legal proceedings; (b) Information held with the intention of furthering a criminal purpose is not subject to legal privilege, and nothing in this Article shall prevent a professional legal advisor from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Partyparty, the competent authority of the requesting Party party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party party may decline a request for information if the information is requested by the requesting Party party to administer or enforce a provision of the tax law of the requesting Partyparty, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party party as compared with a national or citizen of the requesting Party party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting applicant Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure applicant Party would not be able to obtain the information under its own laws for purposes of the information requested would be contrary to public policy administration or enforcement of the requested Partyits own tax laws. 2. This The provisions of this Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information, which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: a) produced for the purposes of seeking or providing legal advice; or b) produced for the purposes of use in existing or contemplated legal proceedings. 4. The requested Party may decline a request for information if the disclosure of the information would be contrary to public policy (ordre public). 5. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request by the Requesting Party where: (a) where the request is not made in conformity with this Agreement, provided that if a request is believed to be deficient in some respect, but other parts of such request meet the requirements of this Agreement, the competent authority of the Requested Party shall provide any information that is responsive to that part of the request that meets the requirements of this Agreement; (b) where the requesting information is requested by the Requesting Party to administer or enforce a provision of the tax law of the Requesting Party, or any requirement connected therewith, which discriminates against a national of the Requested Party as compared with a national of the Requesting Party in the same circumstances; c) the Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or; (cd) where the disclosure of the information requested would be contrary to the public policy of the Requested Party; e) the request is made on or before 31 March 2015 and does not relate to a criminal tax matter in respect of which the Requesting Party has formally commenced a criminal investigation, and the person identified in a request according to paragraph 6(a) of Article 5 has not applied to disclose under a tax disclosure facility of the Requesting Party where he is eligible to do so; accordingly, for avoidance of doubt, the competent authority of the Requested Party may not decline a request by the Requesting Party for information relating to a person who has applied to disclose under a tax disclosure facility of the Requesting Party, whether or not such person has subsequently withdrawn that application; f) the request does not relate to a criminal tax matter in respect of which the Requesting Party has formally commenced a criminal investigation and the information requested relates to i) bank and financial accounts in the Requested Party existing as of the date of signing of this Agreement, or ii) any company, partnership, collective investment fund or scheme, trust, foundation, establishment, or other legal person, fiduciary relationship or insurance policy issued, formed, incorporated, administered or managed in the Requested Party existing as of the date of signing of this Agreement, and the person identified in a request according to paragraph 6(a) of Article 5 is eligible to apply to disclose under a tax disclosure facility of the Requesting Party, and on or before 31 March 2015 such accounts are closed or transferred out of the Requested Party or such legal persons, fiduciary relationships or insurance policies are liquidated, terminated or transferred out of the Requested Party. 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or to: a) supply information which would disclose any trade, business, industrial, commercial or professional secret secret, or any trade process, provided that notwithstanding the foregoing, information described of the type referred to in paragraph 3 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph; b) supply information held by any authorities primarily involved in intelligence gathering activities, and in the case of authorities primarily involved in supervision activities insofar as the information has been gathered solely for financial market supervisory activities; c) supply information on manufacturing costs or other cost information unless and until such date when there is a comprehensive tax convention on income and capital in force between the Contracting Parties providing for a mechanism for the resolution of transfer pricing disputes; or d) carry out administrative measures at variance with the internal laws and administrative practices of the Contracting Party. 3. The Requested Party shall not be required to obtain and provide information that the Requesting Party would be unable to obtain in similar circumstances under its own laws for the purpose of the administration or enforcement of its own tax laws or in response to a valid request by the Requested Party under this Agreement. The statute of limitations of the Requesting Party pertaining to the taxes to which this Agreement applies shall govern a request for information. Accordingly, the expiration of a statute of limitations for determination, assessment or collection of taxes in the Requested Party shall not prevent the Requested Party from obtaining and providing the information requested by the Requesting Party with respect to such taxes. 4. This Agreement shall not impose on a Contracting Party the obligation to obtain or provide information or items subject to legal privilege. For purposes of this paragraph 4, “information or items subject to legal privilege” means information or items that would reveal confidential communications, or items enclosed with or referred to in such communications, between a client and an attorney, solicitor, barrister, or other admitted legal representative, or an employee or representative of such client or such legal representative, where such communications are: a) made for the purpose of seeking or providing legal advice, b) made for the purpose of use in existing or contemplated legal proceedings, or c) made for the purpose of review by a person of the possibility of his taking advantage of a tax disclosure facility. 5. A request for information shall not be refused by the Requested Party on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction disputed by or on behalf of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or person identified in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party according to administer or enforce a provision paragraph 6(a) of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstancesArticle 5. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. (1. ) The competent authority of the requested Contracting Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Contracting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Contracting Party. (2. ) This Agreement shall not impose upon a requested Contracting Party any obligation obligation: a) to provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process.; or b) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Contracting Party under paragraph 4 of Article 5; (3. ) A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. (4. ) The requested Contracting Party shall not be required to obtain and provide information which, which if the requested information was within the jurisdiction of the requesting Party, Contracting Party the competent authority of the requesting Contracting Party would not be able to obtain under its laws or in the normal course of administrative practicelaws. (5. ) The requested Contracting Party may decline a request for information if the information is requested by the requesting Contracting Party to administer or enforce a provision of the tax law of the requesting Contracting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Contracting Party as compared with a national or citizen of the requesting Contracting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where Where the request is not made in conformity with this Agreement; (b) where Where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where Where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Requested Party. 2. This Agreement shall not impose upon a requested Requested Party any obligation to obligation: a) To provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process; or b) To carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Party under paragraph 4 of Article 5. 3. The provisions of this Agreement shall not impose on a Party the obligation to obtain or provide information, which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: a) Produced for the purposes of seeking or providing legal advice or b) Produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 45. The requested Requested Party shall not be required to obtain and provide information which, if which the requested information was within Requesting Party would be unable to obtain in similar circumstances under its own laws for the jurisdiction purpose of the requesting Party, the competent authority administration or enforcement of the requesting Party would not be able to obtain under its own tax laws or in response to a valid request from the normal course of administrative practiceRequested Party under this Agreement. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request for information where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Partypolicy. 2. This The provisions of this Agreement shall not impose upon a requested Party Contracting Party, any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that the information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process, merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister or other admitted legal representatives where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the person under examination or investigation. 45. The requested Requested Party shall not be required to obtain and or provide information which, if that the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its own laws for purposes of the administration or in the normal course enforcement of administrative practiceits own tax laws. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assistassist where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Party; (c) the applicant Party would not be able to obtain the information (i) under its own laws for purposes of administration or enforcement of its own tax laws or (ii) in response to a valid request from the requested Party under this Agreement. 2. This The provisions of this Agreement shall not impose upon on a requested Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications: (a) are communications between a professional legal adviser and a client made in connection with the giving of legal advice to the client; (b) are communications between a professional legal adviser and a client, professional legal adviser acting for the client and another person, or the client and another person made in connection with or in contemplation of legal proceedings and for the purposes of such proceedings; and (c) include items enclosed with or referred to in such communications and made: (i) in connection with the giving of legal advice; or (ii) in connection with or in contemplation of legal proceedings and for the purposes of such proceedings, when the items are in the possession of a person who is entitled to possession of them. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The Requested Party shall not be required to obtain or provide information that if the information requested was within the territorial jurisdiction of the Requesting Party the competent authority of the Requesting Party would not be able to obtain under the laws or in the normal course of administrative practices of the Requesting Party. 2. The competent authority of the requested Requested Party may decline to assist: (a) where the request of the Requesting Party is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except where recourse to such means would give rise to disproportionate difficultydifficulties; orand (c) where the disclosure of the information requested would be contrary to public policy (ordre public) of the requested Requested Party. 23. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Such information includes information relating to communications between advocates, provided attorneys, solicitors or other admitted legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Contracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 34. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a any provision of the tax law laws of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where Where the request is not made in conformity with this Agreement; (b) where Where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where Where the disclosure of the information requested would be contrary to the public policy of the requested Requested Party. 2. This Agreement shall not impose upon a requested Requested Party any obligation to obligation: a) To provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process; or b) To carry out administrative measures at variance with its laws and adminis- trative practices, provided that nothing in this subparagraph shall affect the obligations of a Party under paragraph 4 of Article 5. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Requested Party shall not be required to obtain and provide information which, if which the requested information was within Requesting Party would be unable to obtain in similar circumstances under its own laws for the jurisdiction purpose of the requesting Party, the competent authority administration or enforcement of the requesting Party would not be able to obtain under its own tax laws or in response to a valid request from the normal course of administrative practiceRequested Party under this Agreement. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. (1. ) The competent authority of the requested Contracting Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Contracting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Contracting Party. (2. ) This Agreement shall not impose upon a requested Contracting Party any obligation obligation: a) to provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process; or b) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Contracting Party under paragraph 4 of Article 5. (3. ) A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. (4. ) The requested Contracting Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of which the requesting Party, the competent authority of the requesting Contracting Party would not be able unable to obtain under its own laws or in the normal course of administrative practicepractice in response to a valid request made in similar circumstances from the requested Contracting Party under this Agreement. (5. ) The requested Contracting Party may decline a request for information if the information is requested by the requesting Contracting Party to administer or enforce a provision of the tax law of the requesting Contracting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Contracting Party as compared with a national or the citizen of the requesting Contracting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) Agreement and, in particular, where the requesting Party has requirements referred to in paragraph 5 of Article 5 are not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultymet; or (cb) where the disclosure of the information requested would be contrary to public policy (ordre public) of the requested Requested Party. 2. The Requested Party shall not be required to obtain or provide information that, if the information requested was within the territorial jurisdiction of the Applicant Party, then the competent authority of the Applicant Party would not be able to obtain under the laws or in the normal course of administrative practice of the Applicant Party. 3. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Such information includes information relating to communications between attorneys, provided solicitors or other admitted legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Contracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in subparagraph 1(a) of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that subparagraph. 34. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Applicant Party to administer or enforce a any provision of the tax law laws of the requesting Applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request of the Requesting Party is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy (ordre public) of the requested Requested Party. 2. The Requested Party shall not be required to obtain or provide information that, if the information requested was within the territorial jurisdiction of the Requesting Party, then the competent authority of the Requesting Party would not be able to obtain under the laws or in the normal course of administrative practices of the Requesting Party. 3. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Such information includes information relating to communications between attorneys, provided solicitors, barristers or other admitted legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Contracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in subparagraph 1(a) of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that subparagraph. 34. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a any provision of the tax law laws of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement;; or (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party(ordre public). 2. This The provisions of this Agreement shall not impose upon a requested Party party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister where such communications are: (i) produced for the purposes of seeking or providing legal advice, or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting PartyRequesting party, or any requirement connected therewith, which discriminates against a resident or national or citizen of the requested Requested Party as compared with a resident or national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Contracting Parties shall be kept confidential. 2. Such information confidential and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, 1 and used by such persons or authorities only for such purposes, including the determination of any appealappeal or the oversight of the above. For these purposes, information may be disclosed in public court proceedings or in judicial decisionsproceedings. 32. Such The information may not be used for disclosed to any purpose other than for the purposes stated in Article 1 person or entity or authority without the express written consent of the competent authority of the requested Requested Party. 43. Information provided to a requesting Requesting Party under this Agreement may shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The requested Party shall not be required to obtain or provide information that the applicant Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws, or in response to a valid request from the requested Party under this Agreement. The competent authority of the requested Party may decline to assist: (a) assist where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This The provisions of this Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in Article 45, paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information that would reveal confidential communications between a client and an attorney, solicitor or similar legal representative (hereinafter "professional legal adviser") where such communications: a) are between a professional legal adviser and a client produced for the purposes of the provision of legal advice to the client; or b) are between: (i) a professional legal adviser and a client; (ii) a professional legal adviser acting for the client and another person; or (iii) the client and another person instructed by a professional legal adviser produced for the purposes of existing or contemplated legal proceedings. Nothing in this Agreement shall protect from disclosure: a) anything done or any communication made in furtherance of any illegal or wrongful purpose; or b) any fact observed by a professional legal advisor in the course of his employment as such, showing that any crime or fraud had been committed since the commencement of his employment. 4. The requested Party may decline a request for information if the disclosure of the information would be contrary to public policy (ordre public). 5. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Requested Party. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister where such communications are: (i) produced for the purposes of seeking or providing legal advice, or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering a criminal purpose is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Partyparty. 2. This Agreement shall not impose upon a requested Party party any obligation obligation: (a) to provide items information subject to legal privilege, or nor any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, paragraph 4, V (3)(e) shall not by reason of that fact alone be treated as such a secret or trade process; (b) to carry out administrative measures at variance with its laws and administrative practices; or (c) to supply information requested by the requesting party to administer or enforce a provision of the tax law of the requesting party, or any requirement connected therewith, that would discriminate against a national of the requested party. A provision of tax law, or a connected requirement, shall be considered to be discriminatory against a national of the requested party if it is different or more burdensome with respect to a national of the requested party than with respect to a national of the requesting party in the same circumstances. For purposes of the preceding sentence, a national of the requesting party who is subject to tax on worldwide income is not in the same circumstances as a national of the requested party who is not subject to such taxation. The provisions of this subparagraph shall not be construed to prevent the exchange of information with respect to taxes imposed by the Government of the United States of America or the Government of the Federative Republic of Brazil on branch profits or the excess interest of a branch or on the insurance premium income of foreigners. 3. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 4. The requested Party party shall not be required to obtain and provide information which, if which the requested information was within requesting party would be unable to obtain in similar circumstances under its own laws for the jurisdiction purpose of the requesting Party, the competent authority administration/enforcement of the requesting Party would not be able to obtain under its own tax laws or in the normal course of administrative practice. 5. The requested Party may decline response to a valid request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of from the requested Party as compared with a national or citizen of the requesting Party in the same circumstancesparty under this Agreement. 1. All Any information provided and received by the competent authorities of the Parties requesting party under this Agreement shall be kept confidential. 2. Such information shall treated as confidential and may be disclosed only to persons or authorities (including courts and administrative bodies) in the jurisdiction of the requesting party concerned with the purposes specified assessment or collection of, the enforcement or prosecution in Article 1respect of, or the determination of appeals in relation to, the taxes covered by this Agreement, or to supervisory bodies, and used by such only to the extent necessary for those persons, authorities or supervisory bodies to perform their respective responsibilities. Such persons or authorities shall use such information only for such purposes, including . They may disclose the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such The information may shall not be used for disclosed to any purpose other than for the purposes stated in Article 1 person or entity or authority or any other jurisdiction without the express written consent of the competent authority requested party. 2. Any liability under the domestic law of the requested Party. 4. Information requesting party arising from the requesting party’s use of information provided to a requesting Party under this Agreement may not shall be disclosed to any other jurisdictionsolely the responsibility of the requesting party.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where Where the request is not made in conformity with this Agreement; (b) where Where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where Where the disclosure of the information requested would be contrary to the public policy of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to obligation: a) To provide items subject to legal privilege, or any information which would disclose trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process; or b) To carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Party under paragraph 4 of Article 5. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of which the requesting Party would not be able unable to obtain in similar circumstances under its own laws for the purpose of the administration or enforcement of its own tax laws or in response to a valid request from the normal course of administrative practicerequested Party under this Agreement. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a citizen or a national or citizen of the requested Party as compared with a citizen or a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist: (a) where the request is not made in conformity with this Agreement;; or (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Partyparty. 2. This The provisions of this Agreement shall not impose upon a requested Party party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister where such communications are: (i) produced for the purposes of seeking or providing legal advice, or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Partyparty, the competent authority of the requesting Party party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party party may decline a request for information if the information is requested by the requesting Party party to administer or enforce a provision of the tax law of the requesting Partyparty, or any requirement connected therewith, which discriminates against a national resident or citizen of the requested Party party as compared with a national resident or citizen of the requesting Party party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties parties shall be kept confidential. 2. Such information confidential and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, 1 and used by such persons or authorities only for such purposes, including the determination of any appealappeal or the oversight of the above. For these purposes, information may be disclosed in public court proceedings or in judicial decisionsproceedings. 32. Such The information may not be used for disclosed to any purpose other than for the purposes stated in Article 1 person or entity or authority without the express written consent of the competent authority of the requested Partyparty. 43. Information provided to a requesting Party under this Agreement may party shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. (1. ) The competent authority of the requested Contracting Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Contracting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the national security or public policy of the requested Contracting Party. (2. ) This Agreement shall not impose upon a requested Contracting Party any obligation obligation: a) to provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process.; or b) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Contracting Party under paragraph 4 of Article 5; (3. ) A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. (4. ) The requested Contracting Party shall not be required to obtain and provide information which, which if the requested information was within the jurisdiction of the requesting Party, Contracting Party the competent authority of the requesting Contracting Party would not be able to obtain under its laws or in response to a valid request made in similar circumstances from the normal course of administrative practicerequested Contracting Party under this Agreement. (5. ) The requested Contracting Party may decline a request for information if the information is requested by the requesting Contracting Party to administer or enforce a provision of the tax law of the requesting Contracting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Contracting Party as compared with a national or citizen of the requesting Contracting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Contracting Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Contracting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Requested Contracting Party. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items information subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in Article 4, paragraph 4, 5(4) shall not by reason of that fact alone be treated as constitute such a secret or trade process.; 3. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 4. The requested Requested Contracting Party shall not be required to obtain and provide provide: (a) information which, if the requested information was within the jurisdiction of the requesting Requesting Contracting Party, the competent authority of the requesting Requesting Contracting Party would not be able to obtain under its laws or laws; (b) information in the normal course possession or control of administrative practicea person other than the taxpayer that does not directly relate to the taxpayer; (c) information relating to a period more than six years prior to the tax period under consideration. 5. The requested Requested Contracting Party may decline a request for information if the information is requested by the requesting Requesting Contracting Party to administer or enforce a provision of the tax law of the requesting Requesting Contracting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Contracting Party as compared with a national or citizen of the requesting Requesting Contracting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assista request for information: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 45, paragraph 4, shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. This Agreement shall not impose on a requested Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: (a) produced for the purposes of seeking or providing legal advice or (b) produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputeddisputed by the taxpayer under examination or investigation. 45. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdictionperson or entity or authority or any other jurisdiction without the express written consent of the competent authority of the requested Party.

Possibility of Declining a Request. 1. The Requested Party shall not be required to obtain or provide information that, if the information requested was within the territorial jurisdiction of the Requesting Party, then the competent authority of the Requesting Party would not be able to obtain under the laws or in the normal course of administrative practices of the Requesting Party. The competent authority of the requested Requested Party may decline to assist: (a) assist where the request of the Requesting Party is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Such information includes information relating to communications between attorneys, provided solicitors or other admitted legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Contracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in subparagraph (a) of paragraph 1 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that subparagraph. 3. The Requested Party may decline a request for information if the disclosure of the information requested would be contrary to public policy (ordre public) of the Requested Party. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a any provision of the tax law laws of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All Any information provided and received by the competent authorities of the Parties a Contracting Party under this Agreement shall be kept confidential. 2. Such information shall treated as confidential and may be disclosed only to persons or authorities (including courts and administrative bodies) in the Contracting Party concerned with the purposes specified assessment or collection of, the enforcement or prosecution in Article 1respect of, and used or the determination of appeals in relation to, the taxes covered by such the Agreement. Such persons or authorities shall use such information only for such purposes, including . They may disclose the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such The information may not be used for disclosed to any purpose other than for person or authority in the purposes stated in Article 1 Contracting Party without the express written consent of the competent authority of the requested Requested Party. 42. Information provided to Any information received by a requesting Contracting Party under this Agreement may not be disclosed to any other jurisdictionperson or authority in non-Contracting Parties.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Partypolicy. 2. This Agreement shall not impose upon a requested Requested Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, paragraph 4, 5(4) shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. This Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister or other admitted legal representatives where such communications are: (i) produced for the purposes of seeking or providing legal advice; or (ii) produced for the purposes of use in existing or contemplated legal proceedings. 4. Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor, or barrister, or admitted legal representative from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 5. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 46. The requested Party shall not be required to obtain and to provide information which, if the requested information was within the jurisdiction of the requesting Party, which the competent authority of the requesting Party would not be able to obtain under its own laws or in the normal course of administrative practicepractice in response to a valid request made in similar circumstances from the requested Party under this Agreement. 57. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a resident or national or citizen of the requested Requested Party as compared with a resident or national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Requested Party. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are (i) produced for the purposes of seeking or providing legal advice; or (ii) produced for the purposes of use in existing or contemplated legal proceedings; (b) Information held with the intention of furthering a criminal purpose is not subject to legal privilege, and nothing in this Article shall prevent a professional legal advisor from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. 1 — The competent authority of the requested Party may decline to assist: (a) where Where the request is not made in conformity with this Agreement; (b) where Where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where Where the disclosure of the information requested would be contrary to the public policy of the requested Party. 2. 2 — This Agreement shall not impose upon a requested Party any obligation to obligation: a) To provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret se- cret or trade process, provided that information described in Article 4, paragraph 4, 4 of article 5 shall not by reason of that fact alone be treated as such a secret or trade process; or b) To carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Party under paragraph 4 of article 5. 3. 3 — A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. 4 — The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of which the requesting Party would not be able unable to obtain in similar circumstances under its own laws for the purpose of the administration or enforcement of its own tax laws or in response to a valid request from the normal course of administrative practicerequested Party under this Agreement. 5. 5 — The requested Party may decline a request for information in- formation if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewiththere- with, which discriminates against a citizen or a national or citizen of the requested Party as compared with a citizen or a national or citizen of the requesting Party in the same circumstances. 1. 1 — All information provided and received by the competent com- petent authorities of the Parties shall be kept confidential. 2. 2 — Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.persons

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assistassist where: (a) where the request is not made in conformity with this Agreement;; or (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret secret, or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law laws of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The Requested Party shall not be required to obtain or provide information that, if the information requested was within the jurisdiction of the Applicant Party, then the competent authority of the Applicant Party would not be able to obtain under the laws or in the normal course of administrative practices of the Applicant Party. The competent authority of the requested Requested Party may decline to assist: (a) assist where the request of the Applicant Party is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Such information includes information relating to communications between attorneys, provided solicitors or other admitted legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Contracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in subparagraph 1(a) of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that subparagraph. 3. The Requested Party may decline a request for information if the disclosure of the information requested would be contrary to public policy (ordre public) of the Requested Party. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Applicant Party to administer or enforce a any provision of the tax law laws of the requesting Applicant Party, or any requirement connected therewith, which discriminates against a resident or national or citizen of the requested Requested Party as compared with a resident or national or citizen of the requesting Applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assistassist where: (a) where the request of the Applicant Party is not made in conformity with this Agreement; (b) where the requesting Applicant Party has not pursued all means available in within its own territory territorial jurisdiction to obtain the informationinformation requested, except where recourse to such means would give rise to disproportionate difficulty; ordifficulties; (c) where the disclosure of the information requested would be contrary to the public policy of the requested Requested Party; (d) the Applicant Party requests information in the possession or control of a person other than the taxpayer under examination, that does not directly relate to the taxpayer; or (e) the Applicant Party would not be able to obtain the information under its laws in similar circumstances; (i) for the purposes of administration or enforcement of its own tax laws; or (ii) in response to a valid request under this Agreement. 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing sentence, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Applicant Party to administer or enforce a any provision of the tax law laws of the requesting Applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assista request of the applicant Party, where: (a) where the request is not made in conformity with this Agreement;Agreement and, in particular, where the requirements of Article 5 are not met; or (b) where the requesting applicant Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation obligation: (a) to provide items information subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 45, paragraph 4, shall not by reason of that fact alone be treated as such a secret or trade process; or (b) to supply information on manufacturing costs or other cost information unless and until such date when there is a comprehensive tax convention on income and capital in force between the Contracting Parties providing for a mechanism for the resolution of transfer pricing disputes; or (c) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Contracting Party under Article 5, paragraph 4 of this Agreement. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting applicant Party would not be able unable to obtain under its own laws or in the normal course of administrative practicepractice in response to a valid request made in similar circumstances from the requested Party under this Agreement. 5. The requested Party may decline a request for information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Contracting Parties shall be kept confidential. 2. Such This information shall may be disclosed only to persons or authorities (including courts and administrative bodies) of the Contracting Parties concerned with the purposes specified in Article 11 including the determination of any appeal, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed used in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party received under this Agreement may must not be disclosed to any other jurisdictionState or sovereign territory not party to this Agreement without the express written consent of the competent authority of the requested Party. 5. Personal data may be transmitted to the extent necessary for carrying out the provisions of this Agreement and subject to the provisions of the law of the requested Party.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all reasonable means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Party. 2. This Agreement shall not impose upon a Party any obligation: (a) to provide information that under the laws of the requested Party any obligation to provide items is (i) subject to legal privilege, privilege or (ii) contains any trade, business, industrial, commercial or professional secret secret, or trade process, provided that information described in paragraph 4(a) of Article 4, paragraph 4, 5 of this Agreement shall not by reason of that fact alone be treated as such a secret or trade process; or (b) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Party under paragraph 4 of Article 5 of this Agreement. For purposes of paragraph 2(a)(i), the term “information subject to legal privilege” means information that would reveal confidential communications between a client and an attorney, where such communications are made for the purpose of seeking or providing legal advice or for the purpose of use in existing or contemplated legal proceedings. 3. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities A provision of the Parties shall tax law, or connected requirement, will be kept confidential. 2. Such information shall considered to be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority discriminatory against a national of the requested PartyParty if it is more burdensome with respect to a national of the requested Party than with respect to a national of the requesting Party in the same circumstances. For purposes of the preceding sentence, a national of the requesting Party who is subject to tax on worldwide income is not in the same circumstances as a national of the requested Party who is not subject to tax on worldwide income. The provisions of this paragraph shall not be construed to prevent the exchange of information with respect to taxes imposed by the Parties on branch profits or on the premium income of foreign insurers. 45. Information provided The requested Party shall not be required to obtain and provide information which the requesting Party would be unable to obtain in similar circumstances under its own laws for the purpose of the administration/enforcement of its own tax laws or in response to a requesting valid request from the requested Party under this Agreement. 6. The statute of limitations of the requesting Party pertaining to the taxes described in paragraph 1 of Article 3 of this Agreement may shall govern a request for information. The expiration of a statute of limitations for taxes of the requested Party shall not be disclosed to any other jurisdictionpreclude the requested Party from obtaining and providing the requested information.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Partyparty. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and a professional legal advisor where such communications are: (i) produced for the purposes of seeking or providing legal advice; or (ii) produced for the purposes of use in existing or contemplated legal proceedings; (b) Information held with the intention of furthering a criminal purpose is not subject to legal privilege, and nothing in this Article shall prevent a professional legal advisor from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Partyparty, the competent authority of the requesting Party party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party party may decline a request for information if the information is requested by the requesting Party party to administer or enforce a provision of the tax law of the requesting Partyparty, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party party as compared with a national or citizen of the requesting Party party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy (ordre public) of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 45, paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade processprocess because it meets the criteria in that paragraph. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, Party and if the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdictionperson or entity or authority or any other jurisdiction without the express written consent of the competent authority of the requested Party.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist: (a) where the request is not made in conformity with this AgreementAgreement and, in particular, where the requirements of Article 5 are not met; (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Partyparty. 2. This Agreement shall not impose upon a requested Party party any obligation obligation: (a) to provide items information that under the laws of the requested party is (i) subject to legal privilegeprivilege or (ii) contains any trade, business, industrial, commercial or professional secret, or any trade process, provided that information that would not otherwise constitute a trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, paragraph 4, shall not by reason of that fact alone be treated as such merely because it is held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity; or (b) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a secret party under paragraph 6 of Article 5 of this Agreement. For purposes of paragraph 2(a), the term “information subject to legal privilege” means information that would reveal confidential communications between a client and an attorney, where such communications are made for the purpose of seeking or trade processproviding legal advice or for the purpose of use in existing or contemplated legal proceedings. 3. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 4. The requested Party party shall not be required to obtain and provide information which, if which the requested information was within requesting party would be unable to obtain in similar circumstances under its own laws for the jurisdiction purpose of the requesting Party, the competent authority administration or enforcement of the requesting Party would not be able to obtain under its own tax laws or in response to a valid request from the normal course of administrative practicerequested party under this Agreement. 5. The requested Party may decline Notwithstanding paragraph 4, the statute of limitations of the requesting party pertaining to the taxes described in paragraph 1 of Article 3 of this Agreement shall govern a request for information if the information is requested by the requesting Party to administer or enforce information. The expiration of a provision statute of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen limitations for taxes of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties party shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of preclude the requested Partyparty from obtaining and providing the requested information. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The Requested Party shall not be required to obtain or provide information that, if the information requested was within the territorial jurisdiction of the Requesting Party, then the competent authority of the Requesting Party would not be able to obtain under the laws or in the normal course of administrative practices of the Requesting Party. The competent authority of the requested Requested Party may decline to assist: (a) assist where the request of the Requesting Party is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Such information includes information relating to communications between attorneys, provided solicitors or other admitted legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Contracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in subparagraph 1(a) of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that subparagraph. 3. The Requested Party may decline a request for information if the disclosure of the information requested would be contrary to public policy (ordre public) of the Requested Party. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a any provision of the tax law laws of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request for information where: (a) where the request is not made in conformity with this Agreement;; or (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Partypolicy. 2. This The provisions of this Agreement shall not impose upon a requested Party Contracting Party, any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that the information described in Paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process, merely because it meets the criteria in that paragraph. 3(a) This Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister or other admitted legal representatives where such communications are: (i) produced for the purposes of seeking or providing legal advice; or (ii) produced for the purposes of use in existing or contemplated legal proceedings; (b) Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister or admitted legal representative from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and or provide information which, if that the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws. The competent authority of the Requested Party may decline to assist where the request is not made in the normal course of administrative practiceconformity with this Agreement. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a resident or national or citizen of the requested Requested Party as compared with a resident or national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assista request of the requesting Party, where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation obligation: a) to provide items information subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, 5 paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade process; or b) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Contracting Party under Article 5 paragraph 4 of this Agreement. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of which the requesting Party would not be able unable to obtain under its own laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assista request of the applicant Party, where: (a) where the request is not made in conformity with this AgreementAgreement and, in particular, where the requirements of Article 5 are not met; (b) where the requesting applicant Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation obligation: a) to provide items information subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, 5 paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade process; b) to supply information on manufacturing costs or other cost information unless and until such date when there is a comprehensive tax convention on income and capital in force between the Contracting Parties providing for a mechanism for the resolution of transfer pricing disputes; or c) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Contracting Party under Article 5 paragraph 4 of this Agreement. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information, which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: a) produced for the purposes of seeking or providing legal advice; or b) produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 45. The requested Party shall not be required to obtain and provide information which, if which the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting applicant Party would not be able unable to obtain under its own laws or in the normal course of administrative practicepractice in response to a valid request made in similar circumstances from the requested Party under this Agreement. 56. The requested Party may decline a request for information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The requested Party shall not be required to obtain or provide information that the applicant Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws. The competent authority of the requested Party may decline to assist: (a) assist where the request is not made in conformity with this Agreement; (b) . The competent authority of the requested Party may decline to assist where the requesting applicant Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means those that would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Partydifficulties. 2. This The provisions of this Agreement shall not impose upon on a requested Party any the obligation to provide items subject to legal privilege, or supply information that would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in Article 45 (Exchange of Information Upon Request), paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Party the obligation to obtain or provide information that would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 4. The requested Party may decline a request for information if the disclosure of the information would be contrary to public policy (ordre public). 5. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 46. The requested Party A request for information shall not be required to obtain and provide information which, if refused on the ground that the period of limitations in the requested information was within Party has expired. Instead, the jurisdiction statute of limitations of the requesting Party, applicant Party pertaining to the competent authority of taxes to which the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline Agreement applies shall govern a request for information. 7. The provisions of this Agreement shall not impose on a Party the obligation to supply information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national of the requested Party. A provision of tax law or citizen connected requirement shall be considered to be discriminatory against a national of the requested Party as compared if it is more burdensome with respect to a national or citizen of the requesting requested Party than with respect to a national of the applicant Party in the same circumstances. 1. All information provided and received by the competent authorities For purposes of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1preceding sentence, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent a national of the competent authority applicant Party who is subject to tax on worldwide income is not in the same circumstances as a national of the requested Party. 4Party who is not subject to tax on worldwide income. Information provided to a requesting Party under The provisions of this Agreement may paragraph shall not be disclosed construed so as to any other jurisdictionprevent the exchange of information with respect to the taxes imposed by the Parties on branch profits, branch-level interest, or the premium income of nonresident insurers or foreign insurance companies.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request for information where: (a) where the The request is not made in conformity with this Agreement;; or (b) where the requesting The Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the The disclosure of the information requested would be contrary to the public policy of the requested Requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to obligation: a) To provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process; or b) To carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Party under paragraph 4 of Article 5. 3. This Agreement shall not impose on a Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representatives where such communications are: i) Produced for the purposes of seeking or providing legal advice; or ii) Produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer under examination or investigation. 45. The requested Requested Party shall not be required to obtain and or provide information which, if that the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws or in the normal course of administrative practicepractice in response to a valid request made in similar circumstances from the Requested Party under this Agreement. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a citizen or national or citizen of the requested Requested Party as compared with a citizen or national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assista request of the requesting Party, where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation obligation a) to provide items information subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, 5 paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade process; or b) to carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Contracting Party under Article 5 paragraph 4 of this Agreement. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of which the requesting Party would not be able unable to obtain under its own laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities Competent Authorities of the Contracting Parties shall be kept treated as confidential. 2. Such This information shall be disclosed only to persons or authorities (including courts and administrative bodies) in the jurisdiction of the Contracting Parties officially concerned with the purposes specified in Article 1, 1 and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 32. Such The information may not be used for any purpose other than for the purposes stated in Article 1 and may not be disclosed to any other person or entity or authority or any other jurisdiction without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) Agreement and, in particular, where the requesting Party has requirements referred to in paragraph 5 of Article 5 are not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultymet; or (cb) where the disclosure of the information requested would be contrary to public policy (ordre public) of the requested Requested Party. 2. The Requested Party shall not be required to obtain or provide informa- tion that, if the information requested was within the territorial jurisdiction of the Applicant Party, then the competent authority of the Applicant Party would not be able to obtain under the laws or in the normal course of administrative practice of the Applicant Party. 3. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial com- mercial or professional secret or trade process. Such information includes infor- mation relating to communications between attorneys, provided solicitors or other admit- xxx legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Con- tracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in subparagraph 1(a) of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that subparagraph. 34. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information infor- mation is requested by the requesting Applicant Party to administer or enforce a provision any provi- sion of the tax law laws of the requesting Applicant Party, or any requirement connected therewiththere- with, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The requested Party shall not be required to obtain or provide information that the applicant Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws, or in response to a valid request from the requested Party under this Agreement. The competent authority of the requested Party may decline to assist: (a) assist where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This The provisions of this Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in Article 45, paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information that would reveal confidential communications between a client and an attorney, solicitor or similar legal representative (hereinafter “professional legal adviser”) where such communications: a) are between a professional legal adviser and a client produced for the purposes of the provision of legal advice to the client; or b) are between: (i) a professional legal adviser and a client; (ii) a professional legal adviser acting for the client and another person; or (iii) the client and another person instructed by a professional legal adviser produced for the purposes of existing or contemplated legal proceedings. Nothing in this Agreement shall protect from disclosure: a) anything done or any communication made in furtherance of any illegal or wrongful purpose; or b) any fact observed by a professional legal advisor in the course of his employment as such, showing that any crime or fraud had been committed since the commencement of his employment. 4. The requested Party may decline a request for information if the disclosure of the information would be contrary to public policy (ordre public). 5. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Partyparty. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and a professional legal advisor where such communications are (ii) produced for the purposes of use in existing or contemplated legal proceedings; (b) Information held with the intention of furthering a criminal purpose is not subject to legal privilege, and nothing in this Article shall prevent a professional legal advisor from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Partyparty, the competent authority of the requesting Party party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party party may decline a request for information if the information is requested by the requesting Party party to administer or enforce a provision of the tax law of the requesting Partyparty, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party party as compared with a national or citizen of the requesting Party party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The Requested Party shall not be required to obtain or provide information that, if the information requested was within the territorial jurisdiction of the Requesting Party, then the competent authority of the Requesting Party would not be able to obtain under the laws or in the normal course of administrative practices of the Requesting Party. The competent authority of the requested Requested Party may decline to assist: (a) assist where the request of the Requesting Party is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Such information includes information relating to communications between attorneys, provided solicitors or other admitted legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Contracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in subparagraph (a) of paragraph 1 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that subparagraph. 3. The Requested Party may decline a request for information if the disclosure of the information requested would be contrary to public policy (ordre public) of the Requested Party. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a any provision of the tax law laws of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request for information where: (a) where the request is not made in in. conformity with this Agreement;; or (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Partypolicy. 2. This The provisions of this Agreement shall not impose upon a requested Party Contracting Party, any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that the information described in Paragraph 4 of Article 4, paragraph 4, S shall not by reason of that fact alone be treated as such a secret or trade process, merely because it meets the criteria in that paragraph. 3(a) This Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister or other admitted legal representatives where such communications are: (i) produced for the purposes of seeking or providing legal advice; or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister or admitted legal representative from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and or provide information which, if that the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its own laws for purposes of-the administration or enforcement of its own tax laws. The competent authority of the Requested Party may decline to assist where the request is not made in the normal course of administrative practiceconformity with this Agreement. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a resident or national or citizen of the requested Requested Party as compared with a resident or national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request for information where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to its national security or public policy of the requested Partypolicy. 2. The Requested Party shall not be required to obtain or provide information that the Requesting Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws or in response to a valid request made in similar circumstances from the Requested Party under this Agreement. 3. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 34. This Agreement shall not impose on a Contracting Party the obligation to obtain or provide information, which would reveal confidential communications between a client and an attorney, solicitor, barrister, or other admitted legal representative where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 5. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputeddisputed by the taxpayer. 46. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties a Contracting Party under this Agreement shall be kept confidential. 2. Such information shall may be disclosed only to persons or authorities (including courts judicial and administrative bodiesauthorities) in the jurisdiction of the Contracting Party concerned with the purposes specified in Article 1, 1 of this Agreement and shall only be used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Requesting Party under this Agreement may shall not be disclosed to any other person or entity or authority or any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement;; or (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party(ordre public). 2. This The provisions of this Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(i) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister where such communications are: produced for the purposes of seeking or providing legal advice, or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a resident or national or citizen of the requested Requested Party as compared with a resident or national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assistassist where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to to: (a) provide items subject to legal privilege, or nor any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, paragraph 4, 5(4) shall not by reason of that fact alone be treated as such a secret or trade process; or (b) carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Party under Article 5(4). 3. For purposes of paragraph 2(a), the term “items subject to legal privilege” means information that would reveal confidential communications between a client and an attorney, where such communications are made for the purpose of seeking or providing legal advice or for the purpose of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and provide information which, if which the requested information was within Requesting Party would be unable to obtain in similar circumstances under its own laws for the jurisdiction purpose of the requesting Party, the competent authority administration or enforcement of the requesting Party would not be able to obtain under its own tax laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided response to a requesting valid request from the Requested Party under this Agreement may not be disclosed to any other jurisdictionAgreement.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assistassist where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Party; c) the applicant Party would not be able to obtain the information: (i) under its own laws for purposes of administration or enforcement of its own tax laws; or (ii) in response to a valid request from the requested Party under this Agreement. 2. This The provisions of this Agreement shall not impose upon on a requested Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications: a) are communications between a professional legal adviser and a client made in connection with the giving of legal advice to the client; b) are communications between a professional legal adviser and a client, professional legal adviser acting for the client and another person, or the client and another person made in connection with or in contemplation of legal proceedings and for the purposes of such proceedings; and c) include items enclosed with or referred to in such communications and made: (i) in connection with the giving of legal advice; or (ii) in connection with or in contemplation of legal proceedings and for the purposes of such proceedings, when the items are in the possession of a person who is entitled to possession of them. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Requested Party. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, privilege or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in Article 4, 5 paragraph 4, 4 shall not by reason of that fact alone or be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputed. 4. The requested Requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Contracting Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) officially concerned with the purposes specified in Article 1, 1 and used by such persons or authorities only for such purposes, including the determination of any appeal, or the oversight of the above. For these purposes, information may be disclosed in public court proceedings or in judicial decisionsproceedings. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Requested Party. 4. Information provided to a requesting Requesting Party under this Agreement may shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The requested Party shall not be required to obtain or provide information that the applicant Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws. Likewise, the competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This The provisions of this Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade processprocess or would violate personal data protection, provided that if any. Notwithstanding the foregoing, information described of the type referred to in Article 45, paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information, which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 4. The requested Party may decline a request for information if the disclosure of the information would be contrary to public policy (ordre public). 5. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting applicant Party to administer or enforce a provision of the tax law of the requesting applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party(“ordre public”). 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement;; or (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party(ordre public). 2. This The provisions of this Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister where such communications are: (i) produced for the purposes of seeking or providing legal advice, or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a resident or national or citizen of the requested Requested Party as compared with a resident or national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Contracting Parties shall be kept confidential. 2. Such information confidential and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, 1 and used by such persons or authorities only for such purposes, including the determination of any appealappeal or the oversight of the above. For these purposes, information may be disclosed in public court proceedings or in judicial decisionsproceedings. 32. Such The information may not be used for disclosed to any purpose other than for the purposes stated in Article 1 person or entity or authority without the express written consent of the competent authority of the requested Requested Party. 43. Information provided to a requesting Requesting Party under this Agreement may shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, paragraph 4, shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions.: 3. (a) Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. (b) Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The Requested Party shall not be required to obtain or provide information that the Requesting Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws. The competent authority of the requested Requested Party may decline to assist: (a) assist where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This The provisions of this Agreement shall not impose upon on a requested Party any the obligation to provide items information subject to legal privilege, privilege or to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in Article 45, paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. The Requested Party may decline a request for information if the disclosure of the information would be contrary to public policy (ordre public). 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All Any information provided and received by the competent authorities of the Parties a Party under this Agreement shall be kept confidential. 2. Such information shall treated as confidential and may be disclosed only to persons or authorities (including courts and administrative bodies) in the jurisdiction of the Party concerned with the purposes specified assessment or collection of, the enforcement or prosecution in Article 1respect of, and used or the determination of appeals in relation to the taxes covered by such this Agreement. Such persons or authorities only for such purposes, including may disclose the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such Notwithstanding the foregoing, the information received by a Party may not be used for any purpose other than taxes or for other purposes when such information may be used for such other taxes or other purposes under the purposes stated in Article 1 without laws of the express written consent of Requesting Party and the competent authority of the requested PartyRequested Party authorises such use. 42. Information The information provided to a requesting the Requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request for information where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to its national security or public policy of the requested Partypolicy. 2. The Requested Party shall not be required to obtain or provide information that the Requesting Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws or in response to a valid request made in similar circumstances from the Requested Party under this Agreement. 3. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 34. This Agreement shall not impose on a Contracting Party the obligation to obtain or provide information, which would reveal confidential communications between a client and an attorney, solicitor, barrister, or other admitted legal representative where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 5. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputeddisputed by the taxpayer. 46. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist:— (a) where the request is not made in conformity with this Agreement;; or (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Partyparty. 2. This The provisions of this Agreement shall not impose upon a requested Party party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister where such communications are— (i) produced for the purposes of seeking or providing legal advice, or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Partyparty, the competent authority of the requesting Party party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party party may decline a request for information if the information is requested by the requesting Party party to administer or enforce a provision of the tax law of the requesting Partyparty, or any requirement connected therewith, which discriminates against a national resident or citizen of the requested Party party as compared with a national resident or citizen of the requesting Party party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties parties shall be kept confidential. 2. Such information confidential and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, 1 and used by such persons or authorities only for such purposes, including the determination of any appealappeal or the oversight of the above. For these purposes, information may be disclosed in public court proceedings or in judicial decisionsproceedings. 32. Such The information may not be used for disclosed to any purpose other than for the purposes stated in Article 1 person or entity or authority without the express written consent of the competent authority of the requested Partyparty. 43. Information provided to a requesting Party under this Agreement may party shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The Requested Party shall not be required to obtain or provide information that, if the information requested was within the territorial jurisdiction of the Applicant Party, then the competent authority of the Applicant Party would not be able to obtain under the laws or in the normal course of administrative practices of the Applicant Party. The competent authority of the requested Requested Party may decline to assist: (a) assist where the request of the Applicant Party is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Such information includes information relating to communications between attorneys, provided solicitors or other admitted legal representatives in their role as such and their clients to the extent that the communications are protected from disclosure under the laws of each Contracting Party. Notwithstanding the foregoing sentences, information described of the type referred to in subparagraph 1(a) of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that subparagraph. 3. The Requested Party may decline a request for information if the disclosure of the information requested would be contrary to public policy (ordre public) of the Requested Party. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Applicant Party to administer or enforce a any provision of the tax law laws of the requesting Applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assistassist where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy of the requested Requested Party; (c) the Applicant Party would not be able to obtain the information: (i) under its own laws for purposes of administration or enforcement of its own tax laws or (ii) in response to a valid request from the Requested Party under this Agreement. The request may be declined if the Applicant Party would not have been able to provide the same information to the Requested Party if the Requested Party had made a similar Request under the Agreement. 2. This The provisions of this Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in paragraph 4 of Article 4, paragraph 4, 6 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3. In conformity with the law pertaining to legal professional privilege of each Contracting Party the provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: (a) communications for the purposes of seeking or providing legal advice; (b) communications for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Applicant Party to administer or enforce a provision of the tax law of the requesting Applicant Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, paragraph 4, shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 6. The requested Party may decline a request for information relating to a period more than six years prior to the tax period under consideration, unless such information 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. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the informationterritory, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Requested Party. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items information subject to legal privilege, or information that would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax liability or claim giving rise to the request is disputeddisputed by the taxpayer. 4. The requested Requested Party shall not be required to obtain and provide information which, if that the requested information was within Requesting Party would be unable to obtain in similar circumstances: (a) under its own laws for the jurisdiction purpose of the requesting Party, enforcement or administration of its own tax laws; or (b) in response to a valid request from the competent authority of the requesting Requested Party would not be able to obtain under its laws or in the normal course of administrative practicethis Agreement. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Contracting Parties shall be kept confidential. 2. Such information shall confidential and may be disclosed only to persons or authorities (including courts and administrative bodiesbodies and, in the case of the British Virgin Islands, a select committee of the House of Assembly) officially concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes or for oversight purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisionsproceedings. 32. Such The information may not be used for disclosed to any purpose other than for the purposes stated in Article 1 person or entity or authority without the express written consent of the competent authority of the requested Requested Party. 43. Information provided to a requesting Requesting Party under this Agreement may shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement;; or (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party(ordre public). 2. This The provisions of this Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3(a) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister where such communications are: (i) produced for the purposes of seeking or providing legal advice, or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering an offence is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a resident or national or citizen of the requested Requested Party as compared with a resident or national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or; (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Party; d) the requesting Party would not be able to obtain the information i. under its own laws for purposes of administration or enforcement of its own tax laws or ii. in response to a valid request from the Requested Party under this Agreement. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in Article 4, paragraph 4, 5(4) shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and a professional legal advisor where such communications are: a) produced for the purposes of seeking or providing legal advice; or b) produced for the purposes of use in existing or contemplated legal proceedings; but this paragraph shall not prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in Article 4, paragraph 4, shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 16. All The requested Party may decline a request for information provided and received by relating to a period more than six years prior to the competent authorities tax period under consideration, unless such information is held in the territory of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons requested Party or authorities (including courts and administrative bodies) concerned with is in the purposes specified in Article 1, and used by such persons possession or authorities only for such purposes, including control of a person within the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority jurisdiction of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Partyparty. 2. This Agreement shall not impose upon a requested Party contracting party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3. This Agreement shall not impose on a contracting party an obligation to provide information held that 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Partyparty, the competent authority of the requesting Party party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party party may decline a request for information if the information is requested by the requesting Party party to administer or enforce a provision of the tax law of the requesting Partyparty, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party party as compared with a national or citizen of the requesting Party party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties contracting parties shall be kept confidential. 2. Such information confidential and shall be disclosed only to persons or authorities (including courts and administrative bodies) officially concerned with the purposes specified in Article 1, 1 and used by such persons or authorities only for such purposes, including the determination of any appeal, or the oversight of the above. For these purposes, information may be disclosed in public court proceedings or in judicial decisionsproceedings. 32. Such The information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Partyparty. 43. Information provided to a requesting Party under this Agreement may party shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) assist where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) Agreement or where the disclosure of the information requested would be contrary to public policy of the requested Party(ordre public). 2. This The provisions of this Agreement shall not impose upon a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret (confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are produced for the purposes of seeking or providing legal advice or for the purposes of use in existing or contemplated legal proceedings) or trade process, provided that information described in Paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Requested Party shall not be required to obtain and provide information which, if which the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Requesting Party would not be able unable to obtain under its own laws for the purpose of the administration or enforcement of its own tax laws or in response to a valid request made in similar circumstances from the normal course of administrative practiceRequested Party under this Agreement. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities authority of the Parties a Contracting Party shall be kept confidential. 2. Such information Information provided to the competent authority of the Requesting Party may be used for purposes other than the purposes stated in Article 1 with the prior express written consent of the Requested Party. 3. Information provided shall be disclosed only to persons or authorities (including courts judicial and administrative bodiesauthorities) concerned with the purposes specified in Article 1, this Agreement and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or; (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Party; d) the requesting Party would not be able to obtain the information (i) under its own laws for purposes of administration or enforcement of its own tax laws or (ii) in response to a valid request from the Requested Party under this Agreement. 2. This Agreement shall not impose upon a requested Contracting Party any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in Article 4, paragraph 4, 5(4) shall not by reason of that fact alone be treated as constitute such a secret or trade process. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and a professional legal advisor where such communications are: (i) produced for the purposes of seeking or providing legal advice; or (ii) produced for the purposes of use in existing or contemplated legal proceedings; 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the taxpayer. 45. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 56. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request by the Requesting Party where: (a) where the request is not made in conformity with this Agreement, provided that if a request is believed to be deficient in some respect, but other parts of such request meet the requirements of this Agreement, the competent authority of the Requested Party shall provide any information that is responsive to that part of the request that meets the requirements of this Agreement; (b) where the requesting information is requested by the Requesting Party to administer or enforce a provision of the tax law of the Requesting Party, or any requirement connected therewith, which discriminates against a national of the Requested Party as compared with a national of the Requesting Party in the same circumstances; c) the Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or; (cd) where the disclosure of the information requested would be contrary to the public policy of the Requested Party; e) the request is made on or before 31 March 2015 and does not relate to a criminal tax matter in respect of which the Requesting Party has formally commenced a criminal investigation, and the person identified in a request according to paragraph 6(a) of Article 5 has not applied to disclose under a tax disclosure facility of the Requesting Party where he is eligible to do so; accordingly, for avoidance of doubt, the competent authority of the Requested Party may not decline a request by the Requesting Party for information relating to a person who has applied to disclose under a tax disclosure facility of the Requesting Party, whether or not such person has subsequently withdrawn that application; f) the request does not relate to a criminal tax matter in respect of which the Requesting Party has formally commenced a criminal investigation and the information requested Party.relates to 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or to: a) supply information which would disclose any trade, business, industrial, commercial or professional secret secret, or any trade process, provided that notwithstanding the foregoing, information described of the type referred to in paragraph 3 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph; b) supply information held by any authorities primarily involved in intelligence gathering activities, and in the case of authorities primarily involved in supervision activities insofar as the information has been gathered solely for financial market supervisory activities; c) supply information on manufacturing costs or other cost information unless and until such date when there is a comprehensive tax convention on income and capital in force between the Contracting Parties providing for a mechanism for the resolution of transfer pricing disputes; or d) carry out administrative measures at variance with the internal laws and administrative practices of the Contracting Party. 3. The Requested Party shall not be required to obtain and provide information that the Requesting Party would be unable to obtain in similar circumstances under its own laws for the purpose of the administration or enforcement of its own tax laws or in response to a valid request by the Requested Party under this Agreement. The statute of limitations of the Requesting Party pertaining to the taxes to which this Agreement applies shall govern a request for information. Accordingly, the expiration of a statute of limitations for determination, assessment or collection of taxes in the Requested Party shall not prevent the Requested Party from obtaining and providing the information requested by the Requesting Party with respect to such taxes. 4. This Agreement shall not impose on a Contracting Party the obligation to obtain or provide information or items subject to legal privilege. For purposes of this paragraph 4, “information or items subject to legal privilege” means information or items that would reveal confidential communications, or items enclosed with or referred to in such communications, between a client and an attorney, solicitor, barrister, or other admitted legal representative, or an employee or representative of such client or such legal representative, where such communications are: a) made for the purpose of seeking or providing legal advice, b) made for the purpose of use in existing or contemplated legal proceedings, or c) made for the purpose of review by a person of the possibility of his taking advantage of a tax disclosure facility. 5. A request for information shall not be refused by the Requested Party on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction disputed by or on behalf of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or person identified in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party according to administer or enforce a provision paragraph 6(a) of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstancesArticle 5. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where Where the request is not made in conformity with this Agreement; (b) where Where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where Where the disclosure of the information requested would be contrary to the public policy of the requested Requested Party. 2. This Agreement shall not impose upon a requested Requested Party any obligation to obligation: a) To provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process; or b) To carry out administrative measures at variance with its laws and administrative practices, provided that nothing in this subparagraph shall affect the obligations of a Party under paragraph 4 of Article 5. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Requested Party shall not be required to obtain and provide information which, if which the requested information was within Requesting Party would be unable to obtain in similar circumstances under its own laws for the jurisdiction purpose of the requesting Party, the competent authority administration or enforcement of the requesting Party would not be able to obtain under its own tax laws or in response to a valid request from the normal course of administrative practiceRequested Party under this Agreement. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting applicant Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Partypolicy. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, privilege or which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may shall not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may shall not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to the public policy (ordre public) of the requested Requested Party. 2. This The Requested Party shall not be required to obtain or provide information that the Requesting Party would not be able to obtain under its own laws for purposes of the administration or enforcement of its own tax laws. 3. The provisions of this Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that information described of the type referred to in Article 45, paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph. 3(a) The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information, which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal representative where such communications are: (i) produced for the purposes of seeking or providing legal advice; or (ii) produced for the purposes of use in existing or contemplated legal proceedings. (b) Information held with the intention of furthering a criminal purpose is not subject to legal privilege, and nothing in this Article shall prevent an attorney, solicitor or barrister from providing the name and address of a client where doing so would not constitute a breach of legal privilege. 5. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 46. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request for information where: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy of the requested Partypolicy. 2. This The provisions of this Agreement shall not impose upon a requested Party Contracting Party, any obligation to provide items subject to legal privilege, or information which would disclose any trade, business, industrial, commercial or professional secret or trade process. Notwithstanding the foregoing, provided that the information described in Paragraph 4 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade process, merely because it meets the criteria in that paragraph. 3. The provisions of this Agreement shall not impose on a Contracting Party the obligation to obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or barrister or other admitted legal representatives where such communications are: (a) produced for the purposes of seeking or providing legal advice; or (b) produced for the purposes of use in existing or contemplated legal proceedings. 4. A request for information shall not be refused on the ground that the tax claim liability giving rise to the request is disputeddisputed by the person under examination or investigation. 45. The requested Requested Party shall not be required to obtain and or provide information which, if that the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Requesting Party would not be able to obtain under its own laws for purposes of the administration or in the normal course enforcement of administrative practiceits own tax laws. 57. The requested Requested Party may decline a request for information if the information is requested by the requesting Requesting Party to administer or enforce a provision of the tax law of the requesting Requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Requested Party as compared with a national or citizen of the requesting Requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) where the request is not made in conformity with this Agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or (c) where the disclosure of the information requested would be contrary to public policy (ordre public) of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items information subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4, paragraph 4, 4 shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information Information provided to the competent authority of the requesting Party may not be used for any purpose other than for the purposes stated in Article 1 without the prior written consent of the competent authority of the requested Party. 3. Information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.

Possibility of Declining a Request. 1. The competent authority of the requested Requested Party may decline to assista request by the Requesting Party where: (a) where the request is not made in conformity with this Agreement, provided that if a request is believed to be deficient in some respect, but other parts of such request meet the requirements of this Agreement, the competent authority of the Requested Party shall provide any information that is responsive to that part of the request that meets the requirements of this Agreement; (b) where the requesting information is requested by the Requesting Party to administer or enforce a provision of the tax law of the Requesting Party, or any requirement connected therewith, which discriminates against a national of the Requested Party as compared with a national of the Requesting Party in the same circumstances; c) the Requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or; (cd) where the disclosure of the information requested would be contrary to the public policy of the Requested Party; e) the request is made on or before 31 March 2015 and does not relate to a criminal tax matter in respect of which the Requesting Party has formally commenced a criminal investigation, and the person identified in a request according to paragraph 6(a) of Article 5 has not applied to disclose under a tax disclosure facility of the Requesting Party where he is eligible to do so; accordingly, for avoidance of doubt, the competent authority of the Requested Party may not decline a request by the Requesting Party for information relating to a person who has applied to disclose under a tax disclosure facility of the Requesting Party, whether or not such person has subsequently withdrawn that application; f) the request does not relate to a criminal tax matter in respect of which the Requesting Party has formally commenced a criminal investigation and the information requested relates to i) bank and financial accounts in the Requested Party existing as of the date of signing of this Agreement, or ii) any company, partnership, collective investment fund or scheme, trust, foundation, establishment, or other legal person, fiduciary relationship or insurance policy issued, formed, incorporated, administered or managed in the Requested Party existing as of the date of signing of this Agreement, and the person identified in a request according to paragraph 6(a) of Article 5 is eligible to apply to disclose under a tax disclosure facility of the Requesting Party, and on or before 31 March 2015 such accounts are closed or transferred out of the Requested Party or such legal persons, fiduciary relationships or insurance policies are liquidated, terminated or transferred out of the Requested Party. 2. This Agreement shall not impose upon on a requested Contracting Party any the obligation to provide items subject to legal privilege, or to: a) supply information which would disclose any trade, business, industrial, commercial or professional secret secret, or any trade process, provided that notwithstanding the foregoing, information described of the type referred to in paragraph 3 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as such a secret or trade processprocess merely because it meets the criteria in that paragraph; b) supply information held by any authorities primarily involved in intelligence gathering activities, and in the case of authorities primarily involved in supervision activities insofar as the information has been gathered solely for financial market supervisory activities; c) supply information on manufacturing costs or other cost information unless and until such date when there is a comprehensive tax convention on income and capital in force between the Contracting Parties providing for a mechanism for the resolution of transfer pricing disputes; or d) carry out administrative measures at variance with the internal laws and administrative practices of the Contracting Party. 3. The Requested Party shall not be required to obtain and provide information that the Requesting Party would be unable to obtain in similar circumstances under its own laws for the purpose of the administration or enforcement of its own tax laws or in response to a valid request by the Requested Party under this Agreement. The statute of limitations of the Requesting Party pertaining to the taxes to which this Agreement applies shall govern a request for information. Accordingly, the expiration of a statute of limitations for determination, assessment or collection of taxes in the Requested Party shall not prevent the Requested Party from obtaining and providing the information requested by the Requesting Party with respect to such taxes. 4. This Agreement shall not impose on a Contracting Party the obligation to obtain or provide information or items subject to legal privilege. For purposes of this paragraph 4, ìinformation or items subject to legal privilegeî means information or items that would reveal confidential communications, or items enclosed with or referred to in such communications, between a client and an attorney, solicitor, barrister, or other admitted legal representative, or an employee or representative of such client or such legal representative, where such communications are: a) made for the purpose of seeking or providing legal advice, b) made for the purpose of use in existing or contemplated legal proceedings, or c) made for the purpose of review by a person of the possibility of his taking advantage of a tax disclosure facility. 5. A request for information shall not be refused by the Requested Party on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction disputed by or on behalf of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or person identified in the normal course of administrative practice. 5. The requested Party may decline a request for information if the information is requested by the requesting Party according to administer or enforce a provision paragraph 6(a) of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstancesArticle 5. 1. All information provided and received by the competent authorities of the Parties shall be kept confidential. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.