Tax information exchange refusals: confidentiality, legal privilege, public policy, and non-discrimination limit disclosure obligations.

Article 7 permits a requested State to decline to obtain or provide information that the applicant could not obtain under its own laws, or where the request fails to conform to the Agreement. It allows refusal to protect trade or business secrets, to preserve legal privilege for confidential communications with legal representatives, and to refuse on public policy grounds. Requests cannot be refused solely because the tax claim is disputed, but may be refused where the information would be used to enforce a discriminatory tax measure against nationals of the requested State.

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