4. Companies in a contracting state whose capital is directly or indirectly controlled by one or more residents of the other contracting state are not subject, in the first state, to a tax or related requirement that is different or more burdensome than the taxation and related requirements to which other identical enterprises of the State of origin are or may be subject. 1. The competent authorities of the contracting states exchange the information necessary for the implementation of the provisions of this Convention or the national legislation of the contracting states relating to the taxes covered by the Convention, provided that the resulting taxation is not contrary to the Convention, in particular with a view to preventing fraud or fraud. Article 1 does not limit the exchange of information. All information received from a State Party is treated in the same way as secret when it comes to information obtained in accordance with the national law of that state. However, if the information is initially considered secret in the state that transmits it, it is disclosed only to persons or authorities (including courts and administrative authorities) who participate in the assessment or collection of the execution or decision on the tax that is the subject of the agreement or the tax decision that is the subject of the agreement. These persons, or may only use this information for such purposes, but may, in the context of public court proceedings, disclose nonformatioms in court decisions. The relevant authorities, through your consulate, develop appropriate conditions, methods and techniques for the issues in which such information is exchanged, including, if necessary, the exchange of information on tax evasion. 4. The competent authorities of the contracting states may communicate directly with each other in order to reach an agreement in accordance with the preceding paragraphs.

The relevant authorities are developing appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure under this article through consultations. In addition, a competent authority may develop appropriate unilateral procedures, conditions, methods and techniques to facilitate the above bilateral actions and the implementation of the mutual agreement procedure.