제18652호                               관              보                          2015. 12. 4.(금요일)
the above. Such persons or authorities shall use the information only for such purposes. They
may disclose the information in public court proceedings or in udicial decisions.
                                                                j


3. n no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a
   I


Contracting State the obligation
                               :


    (a) to carry out administrative measures at variance with the laws and administrative practice
        of that or of the other Contracting State
                                                ;


    (b) to supply information which is not obtainable under the laws or in the normal course of
        the administration of that or of the other Contracting State;


    (c) to supply information which would disclose any trade, business, industrial, commercial or
        professional secret or trade process, or information, the disclosure of which would be
        contrary to public policy (ordre public).
4. f information is re uested by a Contracting State in accordance with this Article, the other
   I                    q


Contracting State shall use its information gathering measures to obtain the re uested           q


information, even though that other State may not need such information for its own tax
purposes. The obligation contained in the preceding sentence is sub ect to the limitations of
                                                                                j


paragraph 3 of this Article but in no case shall such limitations be construed to permit a
Contracting State to decline to supply information solely because it has no domestic interest in
such information.
5. n no case shall the provisions of paragraph 3 of this Article be construed to permit a
   I


Contracting State to decline to supply information solely because the information is held by a
ban , other financial institution, trust, foundation, nominee or person acting in an agency or a
   k


fiduciary capacity or because it relates to ownership interests in a person. n order to obtain such
                                                                                     I


information the tax administration of the re uested Contracting State shall have the power to as
                                            q                                                            k


for the disclosure of information and to conduct investigations and hearings notwithstanding any
contrary provisions in its domestic tax laws."
                                             ARTICLE 2
   E  ach Contracting State shall notify the other, through diplomatic channels, of the completion
of the procedures re uired by its law for the entry into force of this rotocol. This rotocol shall
                    q                                                       P               P


enter into force on the date of receipt of the later of these notifications and its provisions shall
have effect
          :


    (a) with respect to taxes due at source on income credited or payable on or after the first
        day of anuary of the year next following that in which the rotocol enters into force
               J                                                        P                            ;

                                                   7