Spontaneous exchange of information requires sharing tax-relevant intelligence when one State suspects cross-border tax loss.

Spontaneous exchange of information obliges a State to forward tax-relevant information without prior request when it has grounds for supposing cross-border tax loss, a taxpayer's reduction or exemption will affect the other State's tax liability, business dealings routed through other jurisdictions may produce tax savings, artificial profit transfers within groups may produce tax savings, or previously received information has enabled acquisition of further relevant information; each Party must adopt measures and procedures to ensure such information is made available for transmission.

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