Title I — ORGANIZATION AND FUNCTION OF THE BUREAU OF INTERNAL REVENUE may be used by the Bureau of Internal Revenue for tax assessment, verification, audit and enforcement purposes. In case of a request from a foreign tax authority for tax information held by banks and financial institutions, the exchange of information shall be done in a secure manner to ensure confidentiality thereof under such rules and regulations as may be promulgated by the Secretary of Finance, upon recommendation of the Commissioner. (a) (b) (c) (d) (e) (f) (g) The Commissioner shall provide the tax information obtained from banks and financial institutions pursuant to a convention or agreement upon request of the foreign tax authority when such requesting foreign tax authority has provided the following information to demonstrate the foreseeable relevance of the information to the request: The identity of the person under examination or investigation; A statement of the information being sought including its nature and the form in which the said foreign tax authority prefers to receive the information from the Commissioner; The tax purpose for which the information is being sought; Grounds for believing that the information requested is held in the Philippines or is in the possession or control of a person within the jurisdiction of the Philippines; To the extent known, the name and address of any person believed to be in possession of the requested information; A statement that the request is in conformity with the law and administrative practices of the said foreign tax authority, such that if the requested information was within the jurisdiction of the said foreign tax authority then it would be able to obtain the information under its laws or in the normal course of administrative practice and that it is in conformity with a convention or international agreement; and A statement that the requesting foreign tax authority has exhausted all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulties. The Commissioner shall forward the information as promptly as possible to the requesting foreign tax authority. To ensure a prompt response, the Commissioner shall confirm receipt of a request in writing to the requesting tax authority and shall notify the latter of deficiencies in the request, if any, within sixty (60) days from receipt of the request. If the Commissioner is unable to obtain and provide the information within ninety (90) days from receipt of the request, due to obstacles 6 Isla Lipana & Co., the Philippine member firm of the PwC network