Exchange of tax information: bilateral obligation to provide foreseeably relevant records and ownership details, subject to confidentiality. The Agreement requires competent authorities to provide, upon request, any information foreseeably relevant to the administration and enforcement of taxes, including bank and financial records and legal and beneficial ownership across ownership chains, subject to prescribed request contents, procedural timelines, confidentiality obligations, and defined exceptions such as public policy, legal privilege and disproportionate difficulty for publicly traded entities.