Exchange of information upon request empowers cross border tax information access for administration and enforcement purposes.

Exchange of information upon request authorises the transfer of tax relevant information regardless of domestic need or criminal classification; the requested Party must use all relevant information gathering measures to provide bank, fiduciary and ownership data, and may supply depositions and authenticated records subject to domestic law. Requesting authorities must submit written particulars demonstrating foreseeable relevance, including identity of the person, taxable period, nature and form of the information sought, tax purpose, grounds for relevance and possession, and confirmation that domestic means were exhausted. The requested Party must promptly acknowledge requests, notify deficiencies, and explain any inability or refusal to provide information.

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