Exchange of information enables tax authorities to share confidential data for prevention of fraud, subject to strict use and secrecy limits.

The provision requires competent authorities to exchange information and documents necessary to implement the treaty and domestic tax laws, including for prevention of fraud and tax evasion, while mandating that exchanged information be treated as confidential and used only by persons or authorities concerned with assessment, collection, enforcement, prosecution, or appeals; disclosure in public court proceedings is permitted. It also specifies that no State must adopt administrative measures contrary to its laws or practice, supply unobtainable information, or disclose trade secrets or information contrary to public policy.

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