- 1
- A Party shall, without prior request, forward to another Party information of which it has knowledge in the following circumstances:
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- a)the first-mentioned Party has grounds for supposing that there may be a loss of tax in the other Party;
- b)a person liable to tax obtains a reduction in or an exemption from tax in the first-mentioned Party which would give rise to an increase in tax or to liability to tax in the other Party;
- c)business dealings between a person liable to tax in a Party and a person liable to tax in another Party are conducted through one or more countries in such a way that a saving in tax may result in one or the other Party or in both;
- d)a Party has grounds for supposing that a saving of tax may result from artificial transfers of profits within groups of enterprises;
- e)information forwarded to the first-mentioned Party by the other Party has enabled information to be obtained which may be relevant in assessing liability to tax in the latter Party.
- 2
- Each Party shall take such measures and implement such procedures as are necessary to ensure that information described in paragraph 1 will be made available for transmission to another Party.
