Exchange of information upon request requires cross-border provision of tax-relevant and ownership data to competent authorities.

The competent authority of the Requested Party must provide tax-relevant information upon request regardless of its own domestic tax need or whether the conduct is a domestic crime. If existing holdings are insufficient, the Requested Party shall use all relevant information-gathering measures, including depositions and authenticated originals where permissible. The obligation covers information from banks, financial institutions, fiduciaries and legal and beneficial ownership across ownership chains for various entities, subject to a disproportionate-difficulty exception for publicly traced companies and public funds.

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