Exchange of information requires mutual use of information gathering measures with confidentiality and limited legal safeguards.

The treaty requires competent authorities to exchange necessary information, including documents, to administer the Agreement and domestic tax laws; received information is to be treated as secret and disclosed only to persons or authorities concerned with assessment, collection, enforcement, prosecution, appeals or oversight, with permitted judicial disclosure and further use only where both States' laws allow and the supplying authority authorises it. The supplying State must use its information gathering measures to obtain requested information notwithstanding lack of domestic interest, subject to limits that preclude measures contrary to domestic law or disclosure of unobtainable material, trade secrets or information contrary to public policy, and not permitting refusal solely because information is held by financial intermediaries or relates to ownership interests.

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