Exchange of information: obliges reciprocal tax information sharing with confidentiality safeguards and defined limits.

Article 27 requires competent authorities to exchange information and documents necessary to apply the Convention and related domestic tax laws, including for prevention of fraud, evasion and avoidance; exchanged information must be kept secret as under domestic law, with originally secret material disclosed only to designated persons or authorities for assessment, collection, enforcement, prosecution or appeal purposes and usable only for those purposes though disclosure in public court proceedings is permitted. The Article also prohibits obligations to change administrative practices, to provide unobtainable information, or to disclose trade secrets or information contrary to public policy.

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