Article 7 - Spontaneous exchange of information - OECD Member Countries

ARTICLE 7 SPONTANEOUS EXCHANGE OF INFORMATION 1. A Party shall, without prior request, forward to another Party information of which it has knowledge in the following circumstances: (a). the first-mentioned Party has grounds for supposing that there may be a loss of tax in the other Party; (b). a person liable to tax obtains a reduction in or an exemption from tax in the first-mentioned Party which would give rise to an increase in tax or to liability to tax in the other Party; (c). business dealings between a person liable to tax in a Party and a person liable to tax in another Party are conducted through one or more countries in such a way that a saving in tax may result in one or the other Party or in both; (d). a Party has grounds for supposing that a saving of tax may result from artificial transfers of profits within groups of enterprises; (e). information forwarded to the first-mentioned Party by the other Party has enabled information to be obtained which may be relevant in assessing liability to tax in the latter Party. 2. Each Party shall take such measures and implement such procedures as are necessary to ensure that information described in paragraph 1 will be made available for transmission to another Party.