4. The term “dividends” used in this Article means income from shares, mining shares, founder shares or other rights other than claims on debts, profit-sharing and income subject to the same tax treatment as income from shares under the law of the State in which the distributing company is established. 5. In this Article, “taxation” means the taxes which are the subject of this Convention. 4. The Convention shall also apply to all identical or substantially similar taxes levied after the date of signature of the Agreement, in addition to or in place of existing fees. States Parties shall inform each other of substantial changes in their respective tax laws. 2. The competent authorities of the States Parties shall exchange information necessary for the application of the provisions of this Convention or of the domestic law of the States Parties concerning the fees covered by the Convention, to the extent that the taxation provided for in the Convention is not contrary to the Convention. Article 1 does not limit the exchange of information.
All information received by a Contracting State shall be treated secretly in the same manner as information obtained under the domestic law of that State and may be communicated only to persons or authorities (including courts and administrative authorities) who are responsible for the assessment or collection, enforcement or appeal of taxes covered by the Convention. . . .