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 imposition of this convention is not contrary to the Convention. All information received from a State Party is considered secret and is disclosed only to persons or authorities (including courts and administrative services) who participate in the assessment or collection, execution or prosecution, or determination of remedies relating to the taxes covered by the Convention. These persons or authorities may only use this information for such purposes. They may disclose information in the context of public court proceedings or in court decisions. Where a resident of a contracting state believes that the actions of one or both of the contracting states result in or lead to an imposition that does not comply with the provisions of this Convention, he may refer his case to the competent authority of the contracting state of which he resides, regardless of the remedies provided by the domestic law of those States. concerned with entering into an agreement to avoid double taxation and to prevent tax evasion with respect to the taxation of income and income from capital; The competent authorities of the contracting states exchange information that is foreseeable for the application of the provisions of this Convention or for the administration or enforcement of the national legislation of the contracting states relating to taxes of any kind and description imposed on behalf of the States Parties or their political subdivision or their local authorities, provided that the imposition thus provided is not contrary to this Convention. , in particular to prevent fraud and facilitate the enforcement of anti-tax evasion legislation. The exchange of information is not limited by Articles 1 and 2 of this Convention. This paragraph does not affect the corporation`s taxation on the profits on which the dividends are paid. Businesses in a contracting state whose capital is owned or controlled, directly or indirectly, by one or more residents of the other State party, are not subject, in the first state, to a tax or related requirement, which is something other or more burdensome than the taxation and related requirements to which the enterprises of the first state carry out the same activities. whose capital is held or controlled by residents of the first state or is controlled.