- 1.
- For the purpose of this Annex the expression ‘simultaneous tax examination’ means an arrangement between the two States to examine simultaneously and independently, each in its own territory, the tax affairs of a taxpayer or taxpayers in which they have a common or related interest, with a view to exchanging any relevant information which they so obtain. 2.
- The disclosure of information exchanged under the simultaneous examination arrangement is subject to the provisions of the Convention and will be used only for tax purposes.
- Any exchange of information which follows from such examinations either on request or spontaneously will be made through the competent authorities.