Exchange of information upon request: tax authorities must obtain and share bank, ownership and witness records for tax purposes.

Article 5 requires the competent authority of the requested Party to provide, upon request for tax purposes, information regardless of its own tax needs or whether the conduct would be a domestic crime, and to use all relevant information gathering measures to obtain information. It allows depositions and authenticated originals where permitted by law, mandates authority to obtain bank and fiduciary records and legal and beneficial ownership information across entities and arrangements (with a proportionality exception for publicly traded entities), and prescribes required contents of requests and prompt acknowledgement and communication of deficiencies or obstacles.

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