Exchange of information enables cross-border tax enquiries with confidentiality safeguards and limits for trade secrets and public policy.

The competent authorities shall exchange information foreseeably relevant to administering or enforcing taxes covered by the Agreement; such information must be treated as secret and disclosed only to persons or authorities concerned with assessment, collection, enforcement, prosecution or appeals and used only for those purposes. A State need not change laws or provide information unobtainable under its laws, nor disclose trade or professional secrets or information contrary to public policy. Requested States must use their information gathering measures to obtain information even without domestic interest and cannot decline solely because information is held by banks, nominees, agents or in fiduciary capacity.

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