Exchange of information: Treaty requires mutual tax information sharing, subject to confidentiality and limited exceptions. Competent authorities must exchange information foreseeably relevant for applying the Agreement and administering or enforcing domestic tax laws; such information, including documents, must be treated as secret and used only by persons or authorities concerned with assessment, collection, enforcement, prosecution, appeals or oversight, except where both States' laws permit other uses with authorisation. The requested State must use its information gathering measures to obtain information even if it lacks a domestic interest, subject to limitations that do not permit refusal solely because the information is held by banks, financial institutions, nominees or fiduciaries or relates to ownership interests.