Exchange of information: Malaysia must provide documents on Labuan beneficiaries despite their exclusion under the protocol. The Protocol clarifies that the DTAA's residence test does not exclude residents using a territorial taxation principle; that 'may be taxed in the other State' does not prevent residence State taxation; and that persons entitled to Labuan Business Activity Tax Act benefits are excluded from treaty benefits unless a Labuan company elects to be taxed under Malaysia's Income Tax Act. Malaysia will provide under Exchange of Information details on Labuan beneficiaries, with 'information' including documents and certified copies, and the Parties will consult to add Assistance in Collection and Tax Examination Abroad if Malaysia amends domestic law.