S.L. 123.133 Art. 3authority notify place of the and the conduct of the shall be made 1. The obtain or under its own laws. The request is not 2. The obligation to industrial, foregoing, treated as such paragraph. 3. The obligation to representative (a) (b) 4. The of the 5. A claim giving 6. The is requested law of the

If the request referred to in paragraph 2 is granted, the competent of the requested Party conducting the examination shall, as soon as possible, the competent authority of the requesting Party of the time and examination, the authority or person authorised to carry out the examination procedures and conditions required by the requested Party for the examination. All decisions regarding the conduct of the examination by the requested Party conducting the examination. Article 7 Possibility of Declining a Request competent authority of the requested Party shall not be required to provide information that the requesting Party would not be able to obtain laws for purposes of the administration or enforcement of its own tax competent authority of the requested Party may decline to assist where the made in conformity with this Agreement.

provisions of this Agreement shall not impose on a requested Party the provide information which would disclose any trade, business, commercial or professional secret or trade process. Notwithstanding the information of the type referred to in paragraph 4 of Article 5 shall not be a secret or trade process merely because it meets the criteria in that provisions of this Agreement shall not impose on a requested Party the obtain or provide information which would reveal confidential communications between a client and an attorney, solicitor or other admitted legal where such communications are:

produced for the purposes of seeking or providing legal advice; or produced for the purposes of use in existing or contemplated legal proceedings.

requested Party may decline a request for information if the disclosure information would be contrary to public policy (ordre public).

request for information shall not be refused on the ground that the tax rise to the request is disputed.

requested Party may decline a request for information if the information by the requesting Party to administer or enforce a provision of the tax requesting Party, or any requirement connected therewith, which against a national of the requested Party as compared with a national requesting Party in the same circumstances.

Article 8 Confidentiality information received by the competent authorities of a Party shall be treated and may be disclosed only to persons or authorities (including courts administrative bodies) in the jurisdiction of the Party concerned with the collection of, the enforcement or prosecution in respect of, or the of appeals in relation to, the taxes covered by this Agreement. Such authorities shall use such information only for such purposes. They may information in public court proceedings or in judicial decisions. The may not be disclosed to any other person or entity or authority or any jurisdiction without the express written consent of the requested Party. Article 9 Costs competent authorities of the Parties otherwise agree, indirect costs providing assistance shall be borne by the requested Party, and direct in providing assistance (including costs of engaging external advisors with litigation or otherwise necessary to comply with the request) shall the requesting Party. The respective competent authorities shall consult from time to time with regard to this Article, and in particular authority of the requested Party shall consult with the competent authority requesting Party in advance if the costs of providing information with specific request are expected to be significant. Article 10

Mutual Agreement Procedure