Exchange of information: competent authorities must share foreseeably relevant tax data subject to confidentiality and limited use.

Exchange of information requires competent authorities to provide foreseeably relevant information for treaty application or tax administration and enforcement, subject to confidentiality and use limitations limited to tax assessment, collection, enforcement, prosecution, appeals and oversight; disclosure in court proceedings is permitted. The requested State must use its information gathering measures even absent domestic interest, but need not contravene its laws or supply unobtainable information or disclose trade secrets, trade processes, or information contrary to public policy, and may not refuse solely because information is held by financial institutions, nominees, agents or fiduciaries or relates to ownership interests.

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