Exchange of tax information allows limited use of pre-existing documents for investigations and requires non-discriminatory tax treatment.

The Protocol enlarges the definition of company to include establishments ("Anstalten"), allows identity to be determined from equivalent elements when a taxpayer's name is unnecessary, and requires written formal communications and requests for information between competent authorities. It permits exchange of documents created before the Agreement's tax-year scope when foreseeably relevant to a request and usable only in the context of an ongoing investigation or examination, and affirms non-discriminatory tax treatment notwithstanding differences in tax transparency.

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