Exchange of information requires sharing foreseeably relevant tax data with strict confidentiality and limited authorised use.

Competent authorities must exchange information foreseeably relevant for implementing the Agreement or administering and enforcing domestic tax laws; such information is confidential and may be used only for tax assessment, collection, enforcement, prosecution, appeal determination or oversight, except where both States' laws permit authorised other uses. States are not obligated to act contrary to their laws, to provide unobtainable information, or to disclose trade or other protected secrets or information contrary to public policy, but must use information gathering measures to obtain requested information even without domestic interest and cannot refuse solely because information is held by financial intermediaries.

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