662 Acta Apostolicae Sedis - Commentarium Officiale

ligations under this Agreement. Such information may be disclosed in connection with court proceedings related to the performance of the obligations of the HS/ VCS under this Agreement.

2. Information provided to the U.S. Competent Authority pursuant Articles 2 and 5 of this Agreement shall be treated as confidential and may be disclosed only to persons or authorities (including courts and administrative bodies) of the Government of the United States concerned with the assessment, collection, or administration of, the enforcement or prosecution in respect of, or the determina- tion of appeals in relation to, U.S. federal taxes, or the oversight of such functions. Such persons or authorities shall use such information only for such purposes. Such persons may disclose the information in public court proceedings or in judi- cial decisions. The information may not be disclosed to any other person, entity, authority, or jurisdiction. Notwithstanding the foregoing, where the HS/VCS pro- vides prior, written consent, the information may be used for purposes permitted under the provisions of a mutual legal assistance treaty in force between the Par- ties that allows for the exchange of tax information.

Article 10 consUltAtions And Amendments

1. In case any difficulties in the implementation of this Agreement arise, either Party may, independently of the mutual agreement procedure described in paragraph 1 of Article 8 of this Agreement, request consultations to develop appropriate measures to ensure the fulfillment of this Agreement.

2. This Agreement may be amended by written mutual agreement of the Parties. Unless otherwise agreed upon, such an amendment shall enter into force through the same procedures as set forth in paragraph 1 of Article 12 of this Agreement.

Article 11 Annexes

The Annexes form an integral part of this Agreement.

Article 12 term of Agreement

1. This Agreement shall enter into force on the date of signature of this Agreement.