Exchange of Information requires reciprocal tax document sharing with confidentiality and limited public policy exceptions.

The Article requires reciprocal exchange of tax-related information, including documents, for implementing the Agreement and domestic tax laws; received information must be kept secret and disclosed only to designated tax authorities or in public judicial proceedings, with onward disclosure to other authorities of the requesting State needing express written consent. States need not act against their laws or supply unobtainable information or trade secrets, but must use their information-gathering measures to obtain requested information and cannot refuse solely because information is held by financial intermediaries.

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