Exchange of information: tax authorities must share and protect relevant tax information subject to confidentiality and specified limits.

Article 26 requires Contracting States' competent authorities to exchange foreseeably relevant information, including documents, for administering the Agreement and covered domestic tax laws; recipients must treat such information as secret and use it only for tax assessment, collection, enforcement, prosecution, or appeals unless authorised otherwise. Limits allow refusal where obtaining or supplying information would conflict with domestic law or practice, where information is unobtainable in the normal course, or where disclosure would reveal trade secrets or contravene public policy; bank secrecy, fiduciary status, nominee arrangements, or ownership interests do not alone justify refusal.

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