Exchange of information obligations mandate cross border tax data sharing subject to secrecy and narrowly defined legal exceptions.

The competent authorities must exchange foreseeably relevant information, including documents, for administering or enforcing domestic tax laws and must use information gathering measures to obtain requested information even without domestic interest, subject to limits: no obligation to act contrary to law or practice, to provide unobtainable information, or to disclose trade or other secrets or information contrary to public policy; bank or fiduciary holding or ownership interests do not alone permit refusal.

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