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of <h1>Article 27 on cross-border tax information exchange, confidentiality safeguards, and limits on disclosure, secrecy, and public policy</h1> Article 27 mandates that the competent authorities of the contracting states exchange foreseeably relevant tax information, including documents, for implementing the agreement and enforcing domestic tax laws, regardless of Articles 1 and 2. Received information must be kept secret and used only by designated authorities for tax assessment, collection, enforcement, prosecution, appeals, or oversight, though it may be disclosed in public court proceedings or judicial decisions. A state is not required to take measures contrary to its laws or practice, provide unobtainable information, or disclose protected secrets or information against public policy. States must use their information-gathering powers even without domestic tax interest, and cannot refuse solely because information is held by financial institutions, agents, fiduciaries, or concerns ownership interests.
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