Exchange of information enables mutual tax administration and enforcement through foreseeable-relevant data sharing under confidentiality and use limits.

The provision mandates that competent authorities exchange information foreseeably relevant for implementing the Agreement or administering and enforcing domestic tax laws, including documents, while treating received information as secret and restricting its use to specified tax purposes unless authorized otherwise; States need not contravene their laws or disclose unobtainable or protected information, but must use information-gathering measures to obtain requested data and cannot refuse solely because it is held by financial intermediaries or relates to ownership interests.

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