Exchange of information upon request enables access to bank, fiduciary and ownership records to support cross-border tax enquiries.

Article 5 requires the requested Party to provide tax-related information upon request, using all relevant information-gathering measures regardless of its own tax interest, and to supply depositions and authenticated originals where permissible. Competent authorities must have authority to obtain bank, financial, fiduciary and beneficial ownership information for a broad range of entities, subject to a public-entity disproportionate-difficulty exception. Requests must show foreseeable relevance by specifying the person, period, nature and tax purpose of the request, grounds for believing the information is held in the requested Party and conformity with domestic laws and administrative practice; the requested authority must confirm receipt, note deficiencies, and explain any inability to comply.

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