Refusal to provide tax information: public policy and privilege exceptions limit compulsory exchange of information.

The requested Party may decline assistance if a request fails Agreement requirements, if domestic remedies were not exhausted absent disproportionate difficulty, or if disclosure would violate public policy. The Agreement does not require disclosure of trade secrets, communications covered by legal professional privilege, or administrative measures contrary to domestic law, though disputes over the tax claim do not alone justify refusal and the requested Party need not obtain information unobtainable by the requesting Party domestically.

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