Exchange of Information expanded to permit broader cross-border tax information sharing and mutual assistance in tax collection under amended treaty. The Protocol amends the Convention by replacing Article 26 to expand Exchange of Information-allowing requests for any information foreseeably relevant to tax administration or enforcement, including information held by financial institutions or fiduciaries-while preserving confidentiality and permitting disclosure only to authorised tax or judicial bodies and subject to domestic law limitations. It also inserts Article 26A on Assistance in the Collection of Taxes, obliging mutual assistance in recovering amounts finally due to prevent improper enjoyment of treaty relief, subject to enforceability, domestic recovery procedures and safeguards for sovereignty and public policy.