Exchange of information enables mutual tax-relevant data sharing between treaty partners, subject to confidentiality and permitted legal limits.

Competent authorities must exchange foreseeably relevant tax information (including documents) for treaty application and tax administration; received information is secret and usable only by assessment, collection, enforcement, prosecution, appeals or oversight authorities unless both States' laws and the supplying authority permit other uses; States need not take measures contrary to their laws, need not supply unobtainable information, and may withhold trade secrets or information contrary to public policy, but may not refuse solely because the requested State lacks a domestic interest or because information is held by financial institutions or fiduciaries.

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