Exchange of information: tax authorities must share relevant taxpayer information while preserving confidentiality and lawful limits.

Article 26 provides a framework obliging competent authorities to exchange information foreseeably relevant to implementing the Convention or enforcing domestic tax laws; such information must be kept secret and used only for tax assessment, enforcement, prosecution, appeals or oversight, with limited permitted disclosures. States need not act contrary to domestic law, supply unobtainable information, or disclose trade secrets or public policy sensitive material, but must use their information gathering measures to obtain requested information even without a domestic interest, and cannot refuse solely because information is held by banks, financial institutions, nominees or fiduciaries.

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