Exchange of information: Protocol mandates tax information sharing with confidentiality, limited exceptions, and obligation to obtain requested data. The Protocol replaces Article 21 to exempt students present in the other Contracting State for education or training from tax on grants, maintenance payments from persons outside the host State, and study related remuneration, subject to a reasonable duration and a maximum of six consecutive years, and replaces Article 28 to require exchange of information foreseeably relevant to tax administration or enforcement, subject to confidentiality, limited disclosure for tax purposes, specified limitations consistent with domestic law, and an obligation to use information gathering measures even when the requested State has no domestic interest in the information.