S.L. 123.145 Art. 3the competent shall, as soon as examination shall 1. The that the applicant of the the requested with this 2. The the obligation industrial, foregoing, treated as such paragraph. 3. The the obligation communications representative (a) (b) 4. The of the 5. A claim giving rise 6. The is requested by o

If the request referred to in paragraph 2 is acceded to, authority of the Contracting Party conducting the examination be made by the Party conducting the examination. Article 7 Possibility of Declining a Request requested Party shall not be required to obtain or provide information Party would not be able to obtain under its own laws for purposes administration or enforcement of its own tax laws. The competent authority of Party may decline to assist where the request is not made in conformity Agreement.

provisions of this Agreement shall not impose on a Contracting Party to supply information which would disclose any trade, business, commercial or professional secret or trade process. Notwithstanding the information of the type referred to in Article 5, paragraph 4 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 Contracting Party to obtain or provide information, which would reveal confidential 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 to the request is disputed.

requested Party may decline a request for information if the information the applicant Party to administer or enforce a provision of the tax law Party, or any requirement connected therewith, which discriminates of the requested Party as compared with a national of the applicant circumstances.

Article 8 Confidentiality information received by a Contracting Party under this Agreement shall be confidential and may be disclosed only to persons or authorities (including administrative bodies) in the jurisdiction of the Contracting Party the assessment or collection of, the enforcement or prosecution in determination of appeals in relation to, the taxes covered by this Such persons or authorities shall use such information only for such may disclose the information in public court proceedings or in decisions. The information may not be disclosed to any other person or authority or any other jurisdiction without the express written consent of authority of the requested Party. time with regard to this Article so as to establish a procedure for ordinary extra ordinary costs whereby ordinary costs are borne by the requested extraordinary costs are borne by the applicant Party. Article 10 Implementation of Legislation

The Contracting Parties shall enact any legislation necessary to give effect to, the terms of the Agreement.

Article 11 Mutual Agreement Procedure