ARTICLE 6

Tax Examinations Abroad

(1) By reasonable notice given in advance, the requesting Contracting State may request that the requested Contracting State allow representatives of the competent authority of the requesting Contracting State to enter the territory of the requested Contracting State, to the extent permitted under its 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 Contracting State shall notify the competent authority of the requested Contracting State of the time and place of the intended meeting with the individuals concerned.

(2) At the request of the competent authority of the requesting Contracting State, the competent authority of the requested Contracting State may allow representatives of the competent authority of the requesting Contracting State to be present at the appropriate part of a tax examination in the requested Contracting State.

(3) If the request referred to in paragraph (2) is acceded to, the competent authority of the requested Contracting State conducting the examination shall, as soon as possible, notify the competent authority of the requesting Contracting State about the time and place of the examination, the authority or official designated to carry out the examination and the procedures and conditions required by the requested Contracting State for the conduct of the examination. All decisions with respect to the conduct of the tax examination shall be made by the requested Contracting State conducting the examination.