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e) The reasons for believing that the information requested is foreseeably relevant to the tax administration

and enforcement of the tax law of the Requesting Party, with respect to the person identified in subparagraph a)

of this paragraph,

f) Grounds for believing that the information requested is held in the Requested Party or is in the possession

of or obtainable by a person within the jurisdiction of the Requested Party,

g) To the extent known, the name and address of any person believed to be in possession of the requested

information,

h) A statement that the request is in conformity with the laws and administrative practices of the Requesting

Party, that if the requested information was within the jurisdiction of the Requesting Party then the competent

authority of the Requesting Party would be able to obtain the information under the laws of the Requesting Party

or in the normal course of administrative practice and that it is in conformity with this Agreement,

i) A statement that the Requesting Party has pursued all means available in its own territory to obtain the

information, except those that would give rise to disproportionate difficulties.

6. The competent authority of the Requested Party shall acknowledge receipt of the request to the competent

authority of the Requesting Party and shall use its best endeavours to forward the requested information to the

Requesting Party with the least reasonable delay.

ARTICLE 6

TAX EXAMINATIONS (OR INVESTIGATIONS) ABROAD

1. By reasonable notice given in advance, the Requesting Party may request that the Requested Party allow

representatives of the competent authority of the Requesting Party to enter the territory of the Requested Party,

to the extent permitted under its domestic laws, to interview individuals and examine records with the prior written

consent of the individuals or other persons concerned. The competent authority of the Requesting Party shall

notify the competent authority of the Requested Party of the time and place of the intended meeting with the

individuals concerned.

2. At the request of the competent authority of the Requesting Party, the competent authority of the

Requested Party may, in accordance with its domestic laws, allow representatives of the competent authority of

the Requesting Party to be present at the appropriate part of a tax examination in the territory of the Requested

Party.

3. If the request referred to in paragraph 2 is granted, the competent authority of the Requested Party

conducting the examination shall, as soon as possible, notify the competent authority of the Requesting Party of

the time and place of the examination, the authority or person authorised to carry out the examination and the

procedures and conditions required by the Requested Party for the conduct of the examination. All decisions

regarding the conduct of the examination shall be made by the Requested Party conducting the examination, in

accordance with its domestic laws.

ARTICLE 7

POSSIBILITY OF DECLINING A REQUEST

1. The competent authority of the Requested Party may decline to assist:

a) Where the request is not made in conformity with this Agreement;

b) Where the Requesting Party has not pursued all means available in its own territory to obtain the

information, except where recourse to such means would give rise to disproportionate difficulty; or

c) Where the disclosure of the information requested would be contrary to the public policy (ordre public) of

the Requested Party.

2. This Agreement shall not impose upon a Requested Party any obligation: