Refusal of information requests under DTAA: procedural, privilege, public policy, exhaustion and non discrimination limits apply.

Refusal of assistance is permitted where requests fail formal Agreement requirements, where domestic means have not been exhausted unless disproportionate difficulty exists, or where disclosure would violate public policy. Contracting Parties need not provide information protected by legal privilege or trade secrets, nor undertake administrative measures contrary to their laws, subject to Article 5(4). Requests cannot be refused solely because the tax claim is disputed, and Parties are not required to obtain information the requester could not obtain under similar domestic law circumstances. Discriminatory requests may be declined.

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