Exchange of information: mutual tax information sharing with confidentiality and limited disclosure; exceptions for legal and public policy constraints.

Article 25 mandates mutual exchange of information foreseeably relevant to applying the treaty and domestic tax laws, permitting transfer of documents and certified copies. Exchanged information must be kept secret and used only by authorized persons for assessment, collection, enforcement, prosecution, appeals or oversight, and may appear in public court proceedings. Limits exist where providing information would conflict with domestic law or administrative practice, be unobtainable in the normal course, or disclose trade or professional secrets or be contrary to public policy. States must use their information gathering powers even without domestic interest and cannot refuse solely because information is held by banks, nominees or fiduciaries.

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