Pursuant to Article 26 of the Convention between the Republic of Korea and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed at Seoul on 25 October 1978, and the provisions with regard to the exchange of information in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, done at Strasbourg on 25 January 1988 as amended the competent authorities referred to in Paragraph 2 of this Memorandum of Understanding (the ‘MOU’) will exchange information automatically or spontaneously and intensify mutual cooperation within the scope of both simultaneous tax examinations and tax examinations abroad.