Protection of persons limits on cross-border tax assistance while requiring information gathering despite lack of domestic interest.

The Convention preserves protections afforded by the requested State's laws and limits assistance where measures would conflict with domestic laws or public policy, disclose protected secrets, enforce discriminatory tax rules, or impose disproportionate burden. It obliges the requested State to use its information gathering measures to obtain requested information even if not needed for its own tax purposes, and prohibits refusal solely because information is held by banks, financial institutions, nominees, agents, fiduciaries or concerns ownership interests.

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