This Protocol, signed 18 December 2012, amends the Double Taxation Avoidance Agreement between Bahrain and Brunei Darussalam from 14 January 2008. It replaces the original Article 27 concerning the Exchange of Information. The new article mandates the exchange of foreseeably relevant information for enforcing domestic tax laws of every kind. Any information received must be treated as secret and disclosed only to authorities involved in tax assessment or enforcement. A state must use its information-gathering measures to obtain requested data, even if it has no domestic tax interest, limited only by provisions preventing the violation of its own laws or the disclosure of trade secrets or public policy. However, a state cannot decline a request solely because information is held by a bank or financial institution.
PROTOCOL AMENDING the Agreement between the Government of KINGDOM OF BAHRAIN and the Government of His Majesty the Sultan and Yang Di-Pertuan of BRUNEI DARUSSALAM for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
The Government of the Kingdom of Bahrain and the Government of His Majesty the Sultan and Yang Di-Pertuan of Brunei Darussalam,
Desiring to amend the Agreement between the Government of the Kingdom of Bahrain and the Government of His Majesty the Sultan and Yang Di-Pertuan of Brunei Darussalam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Manama on the 14th of January 2008 (hereinafter referred to as "the Agreement"),
Have agreed as follows:
Contents
Article 1
Article 2
Article 3
Article 1
The text of Article 27 of the Agreement is deleted and replaced by the following:
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