Exchange of information expanded - treaty now mandates broader information exchange, tax collection assistance and anti abuse limits. Amendment revises taxes covered and adds mechanisms: an Associated Enterprises adjustment obliges competent authorities to make appropriate tax adjustments where one State taxes profits attributable to an enterprise of the other State; Article 28 expands Exchange of Information to all foreseeably relevant information, mandates secrecy, permits use of information gathering measures even without domestic interest and covers information held by financial intermediaries; Article 28A establishes mutual assistance in collection and conservancy measures under domestic law limits; Article 28B imposes limitation of benefit and preserves domestic anti abuse and CFC rules.