Article 7 Spontaneous exchange of information

1.

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.