Protocol

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....ng Parties") on the exchange of information on tax matters, the Contracting Parties have agreed upon the following provisions, which are an integral part of this Agreement: 1. With respect to subparagraph (f) of paragraph 1 of Article 4, it is understood that the term company includes also establishments ("Anstalten"). 2. With respect to subparagraph a of paragraph 5 of Article 5 ....

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....ill be in writing between the earlier mentioned competent authorities or their authorised entities, whereas the possibility of direct consultation is being given. 5. Although the Agreement allows only for requests for information with regard to tax years beginning on or after April 1, 2013, the Agreement provides for exchange of documents or information created in or derived from a date preceding....