Exchange of information upon request: requests must show foreseeable relevance and prior exhaustion of domestic means before seeking assistance.

The competent authority of the requested Party must provide, upon request and notwithstanding whether it needs the information for its own tax purposes, tax-relevant information obtainable through all relevant information-gathering measures, including depositions and authenticated originals where permitted, and must have authority to obtain information from banks, financial institutions, fiduciaries, and regarding legal and beneficial ownership across ownership chains; requests must show foreseeable relevance and that domestic means were pursued unless disproportionate difficulty exists.

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