2. pants

The competent authority of each

State shall inform its counterpart of the other State of its

choice of potential cases for simultaneous tax examinations, for

which it used the selection criteria described below. It shall

explain, as far as possible, why it has chosen these cases and

provide the information leading to its proposals, together with

any other relevant information, as well as its statute of

limitation applicable to the cases proposed for simultaneous

examinations.