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    <title>Confidentiality of Arbitration Proceedings</title>
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    <description>The provision treats arbitration panel members, up to three staff per member, and prospective arbitrators (only as needed to verify qualifications) as persons to whom tax information may be disclosed; information received by them and information received by competent authorities from the panel is regarded as exchanged under the Covered Tax Agreement&#039;s exchange-of-information and administrative-assistance provisions. Competent authorities must obtain written confidentiality and nondisclosure undertakings from panel members and staff prior to their participation, consistent with the Covered Tax Agreement and applicable domestic law.</description>
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      <description>The provision treats arbitration panel members, up to three staff per member, and prospective arbitrators (only as needed to verify qualifications) as persons to whom tax information may be disclosed; information received by them and information received by competent authorities from the panel is regarded as exchanged under the Covered Tax Agreement&#039;s exchange-of-information and administrative-assistance provisions. Competent authorities must obtain written confidentiality and nondisclosure undertakings from panel members and staff prior to their participation, consistent with the Covered Tax Agreement and applicable domestic law.</description>
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