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. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege or which would disclose 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.

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 policypolicy (“ordre public”). 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 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 public policy. 2. This Agreement shall not impose upon on a requested Party 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 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. 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 party shall not be required to obtain and provide information which, which if the requested information was within the jurisdiction of the requesting Party, party 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. 5. 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.

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 policypolicy 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 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, 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 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 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.

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 policypolicy of the requested Party. 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 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.

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 policypolicy (ordre public). 2. This Agreement shall not impose upon a requested 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 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.

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. 2. This Agreement shall not impose upon on a requested 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 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. 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 policypolicy of the requested Party. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege or which would disclose privilege, nor 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 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 which the 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 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.

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 policypolicy (ordre public). 2. This Agreement shall not impose upon on a requested Party any the obligation to provide items subject to legal privilege or which would disclose any trade, business, industrial, commercial or professional secret or trade process, 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 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.

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 policypolicy (“ordre public”). 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 Article 4, paragraph 4, 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 policypolicy (“ordre public”). 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 Article 4, paragraph 4, 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 policypolicy (“ordre public”). 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 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 policypolicy (ordre public). 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 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. This Agreement shall not impose on a contracting party an obligation to 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 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.

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. 2. This Agreement shall not impose upon on a requested Party any the obligation to provide items information subject to legal privilege or which would disclose any trade, business, industrial, commercial or professional secret or trade process, 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 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 or provide information which, if the requested information was within the jurisdiction of the requesting Party, Party the competent authority of the requesting Party would not be able to obtain under its own 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.

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 policypolicy ("ordre public"). 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 Article 4, paragraph 4, 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, which if the requested information was within the jurisdiction of the requesting Party, Party the competent authority of the requesting request- ing 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 re- quirement 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.

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 policypolicy (ordre public). 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 Article 4, paragraph 4, 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.

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 policypolicy (“ordre public”). 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 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, which if the requested information was within the jurisdiction of the requesting Party, Party 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. 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.

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. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege or which would disclose 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.

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. 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 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.

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 policypolicy (ordre public). 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 Article 4, paragraph 4, 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege privilege, or supply information which would disclose 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.

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 policypolicy (“ordre public”). 2. This Agreement shall not impose upon a requested 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 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.

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 national security or public policy. 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 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 difficultydifficulties; or (c) where the disclosure of the information requested would be contrary to public policy. 2. This Agreement shall not impose upon on a requested Party any the obligation to provide supply 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 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 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 or 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 own laws or in for the normal course purposes of administrative practicethe administration and enforcement of its own tax laws. 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.

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 policypolicy (ordre public). 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 Article 4, paragraph 4, 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.

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. 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 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, 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 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.

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. 2. This Agreement shall not impose upon a requested Party any obligation 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 Article 4, paragraph 4, 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 policypolicy (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 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, 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.

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 policypolicy of the requested Party. 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 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 ta.x 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.

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 public policy. 2. This Agreement shall not impose upon a requested Party 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 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 party shall not be required to obtain and provide information which, which if the requested information was within the jurisdiction of the requesting Party, party 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. 5. 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.

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 policypolicy of the requested Party. 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 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 whichwhich , 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 therewiththerewith , 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.

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 policypolicy (ordre public). 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 Article 4, paragraph 4, 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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. 2. This Agreement shall not impose upon on 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 Article 45, 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist, 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 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 policypolicy (ordre public). 2. This Agreement shall not impose upon on a requested 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 described in Article 5 (4, paragraph 4, ) shall not by reason of that fact alone be treated as such a secret or trade process. 3. In no case shall the provisions of this Agreement be construed so as to impose on a Contracting Party the obligation to supply information which is not obtainable under the laws or in the normal course of the administration of that or the other Contracting 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 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.

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 of the information requested would be contrary to public policy. 2. This Agreement shall not impose upon a requested Party any obligation to supply information subject to legal privilege, or to provide items subject to legal 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, 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 Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting applicant Party, the competent authority of the requesting applicant 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.

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. 2. This Agreement shall not impose upon on a requested Party any the obligation to provide supply 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, 4 shall not by reason of that fact alone be treated as such a secret or trade process. The term "legal privilege" shall be interpreted as to include legal privilege which is established by the Courts, based on settled case law. 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, which if the requested information was within the jurisdiction of the requesting Party, 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. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 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.

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 policypolicy (ordre public). 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, 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 policypolicy 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 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, 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 national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances.

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 policypolicy (ordre public) of the requested party; or (d) where the competent authority of the requesting party would not be able to obtain the information under its laws or in the normal course of administrative practice if the requested information were within the jurisdiction of the requesting party. 2. This Agreement shall not impose upon a requested Contracting Party any obligation obligation: (a) to provide items information subject to legal privilege as provided for under the domestic law of the relevant party or which would disclose any trade, business, industrial, commercial or professional secret or trade process, provided that information . Information described in paragraph 5 of Article 4, paragraph 4, 5 shall not by reason of that fact alone be treated as constitute such a secret or trade process; (b) to carry out administrative measures at variance with its laws and administrative practices, provided nothing in this subparagraph shall affect the obligations of a Contracting Party under paragraph 5 of Article 5. 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 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.

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 jurisdiction 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 policypolicy (ordre public) of the requested Party. 2. This Agreement shall not impose upon on a requested Party any the obligation to provide items subject to legal privilege or which would disclose any trade, business, industrial, commercial or professional secret or trade process, 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 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 or 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. 4. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 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 citizen or citizen a resident of the requested Party as compared with a national citizen or citizen a resident of the requesting Party in the same circumstances.

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 public policypolicy (“ordre public”). 2. This Agreement shall not impose upon a requested Party 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 Article 4, paragraph 4, 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 party shall not be required to obtain and provide information which, which if the requested information was within the jurisdiction of the requesting Party, party 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. 5. 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.

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 public policy. 2. This Agreement shall not impose upon a on the requested 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, 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 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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. 2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege or 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 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.

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. 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 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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. 2. This Agreement shall not impose upon on a requested 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 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. 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, which if the requested information was within the jurisdiction of the requesting Party, 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.

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 public policy. 2. This Agreement shall not impose upon a requested Contracting 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, 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 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 practice. 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.

Possibility of Declining a Request. assist: 1. The competent authority of the requested Party party may decline to assist:to (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 public policypolicy . 2. This Agreement shall not impose upon a requested Party 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 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 party shall not be required to obtain and provide information which, which if the requested information was within the jurisdiction of the requesting Party, party 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. 5. 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.

Possibility of Declining a Request. 1. The competent authority of the requested Party may decline to assist: (a) a. where the request is not made in conformity with this Agreement; (b) 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) c. where the disclosure of the information requested would be contrary to public policypolicy (ordre public). 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 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, which if the requested information was within the jurisdiction of the requesting Party, 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.