Exchange of Information enables confidential sharing of tax-related documents between treaty partners, subject to secrecy and narrow exceptions.

Article 26 creates an Exchange of Information duty for competent authorities to share necessary tax-related information and documents for implementing the Agreement, domestic tax laws, or preventing tax evasion, subject to a confidentiality obligation limiting disclosure to persons or authorities involved in tax assessment, collection, enforcement, prosecution, or appeals and permitting use only for those purposes; public court disclosure is allowed. The Article excludes any obligation to adopt measures contrary to domestic law or practice, to supply unobtainable particulars, or to disclose trade secrets or information contrary to public policy.

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