Page:United States Statutes at Large Volume 62 Part 2.djvu/458

 or more burdensome taxes than are the citizens of such other con- tracting State residing in its territory. As used in this paragraph, "Citizens." (a) the term "citizens" includes all legal persons, partnerships, and associations created or organized under the laws in the respective contracting States, and "Taxes." (b) the term "taxes" means taxes of every kind or description whether national, Federal, state, provincial or municipal. (2) It is agreed that section 25, paragraph 5, of the Danish law No. 391 of July 12, 1946, prescribing an addition of 50 percent to the capital increment tax on corporations in cases where more than 50 percent of the entire stock capital is owned by a single shareholder residing outside Denmark, shall not be applicable when the share- holder in question is a resident of the United States or a United States corporation or other entity. Article XVII Exchange of inor- The competent authorities of the contracting States shall exchange such information (being information available under the respective taxation laws of the contracting States) as is necessary for carrying out the provisions of the present Convention or for the prevention of fraud or the administration of statutory provisions against tax avoid- ance in relation to the taxes which are the subject of the present Con- vention. Any information so exchanged shall be treated as secret axid shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information shall be exchanged which would disclose any trade secret or trade process. Article XVIII Collection of taxes, (1) The contracting States undertake to lend assistance and sup- port to each other in the collection of the taxes which are the subject of the present Convention, together with interest, costs, and additions to the taxes. (2) In the case of applications for enforcement of taxes, revenue claims of each of the contracting States which have been finally determined may be accepted for enforcement by the other contracting State and may be collected in that State in accordance with the laws applicable to the enforcement and collection of its own taxes. (3) Any application shall include a certification that under the laws of the State making the application the taxes have been finally determined. (4) The assistance provided for in this Article shall not be accorded with respect to the citizens, corporations, or other entities of the State to which application is made, except as is necessary to insure that the exemption or reduced rate of tax granted under the present Convention to such citizens, corporations, or other entities shall not be enjoyed by persons not entitled to such benefits. 1736 TREATIES [62 STAT.

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