Article 22 - Secrecy

Secrecy of tax information limits disclosure to tax authorities and requires prior authorisation for other uses.

Article 22 requires that information obtained under the Convention be treated as secret and protected as under the supplying Party's domestic law, with personal data safeguards where needed. Disclosure is limited to persons or authorities concerned with tax assessment, collection, recovery, enforcement, prosecution, appeals or oversight, and use is confined to those purposes, except that information may appear in public court proceedings or judicial decisions. Reservations bar use for specified tax categories, and use for other purposes or onward transmission to a third Party requires the supplying Party's law and prior competent-authority authorisation.