Exchange of tax information between contracting states is permitted, secret, and limited by defined disclosure exceptions. Competent authorities may exchange foreseeably relevant tax information, including documents, for implementing the Agreement or administering and enforcing domestic tax laws; such information must be treated as secret and used only by designated assessment, collection, enforcement, prosecution, appeals or oversight authorities, with permitted disclosure in public court proceedings. A State need not act against its laws, provide information not obtainable under its laws, or disclose trade or public policy sensitive secrets, but must use information gathering measures to obtain requested information even without a domestic interest, and may not refuse solely because information is held by banks, financial institutions, nominees, fiduciaries or concerns ownership interests.