Exchange of information upon request: authorities must obtain and share taxpayer banking and ownership records when foreseeably relevant.

Article 5 requires the requested Party's competent authority to provide, for specified tax purposes, information upon request regardless of whether the conduct would be a domestic crime, and to use all relevant information gathering measures to obtain such information. Authorities must, within the limits of domestic law, supply depositions and authenticated originals, obtain bank, financial institution and fiduciary records, and disclose ownership and beneficial ownership information across ownership chains, subject to proportionality limits for public companies and collective investment vehicles. Requests must show foreseeable relevance and conformity with domestic law and exhausted domestic means except where disproportionate difficulties exist.

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