Pearse Doherty (Donegal South West, Sinn Fein) | Oireachtas source

I had thought from the Minister of State's replies there might have been a further provision. Article 26 provides - and this is the caveat - that competent authorities of the contracting states shall exchange such information as is foreseeably relevant for carrying out the provisions of this agreement or to the administration or enforcement of domestic laws. The BEPS programme - this is why I asked the Minister of State to judge this against what is envisaged under BEPS - envisages spontaneous information exchange, particularly in relation to multinational companies, although it is not foreseeably relevant for carrying out the provisions of the agreement. I contend it proposes something considerably in excess of what is contained in this double taxation agreement.