Contracting States must exchange tax information to prevent fraud, respecting confidentiality and legal boundaries under Convention rules.
The competent authorities of the Contracting States are required to exchange information necessary for implementing the provisions of the Convention or domestic tax laws, particularly to prevent tax fraud or evasion. This exchange is not limited by Article 1, and any information received must be treated as confidential, disclosed only to relevant authorities involved in tax-related matters. The information can be used in public court proceedings or judicial decisions. However, a Contracting State is not obligated to perform actions contrary to its laws, provide unobtainable information, or disclose sensitive trade secrets or information against public policy.
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