Exchange of information requires cross-border tax information sharing with confidentiality protections and limited public policy exceptions.

The Article requires competent authorities of contracting states to exchange information foreseeably relevant to applying the agreement and administering or enforcing domestic tax laws, treating received information as secret and restricting use to tax assessment, collection, enforcement, prosecution, appeals, or oversight; other uses require mutual legal permission and supplying-state authorization. Limits permit refusal only where disclosure would contravene a state's laws or administrative practice, is unobtainable under normal administration, or would reveal trade or professional secrets or violate public policy, but ownership through banks, nominees, agents or fiduciaries does not alone justify nondisclosure.

---

---

---