Exchange of information: competent authorities may obtain and share taxpayer relevant information for tax administration and enforcement.

Competent authorities must exchange information foreseeably relevant to implementing the Agreement or administering or enforcing domestic tax laws; received information is to be treated as secret and disclosed only to persons or authorities involved in assessment, collection, enforcement, prosecution, appeals or oversight and used solely for those purposes unless both States' laws and the supplying State authorise other use. Limitations permit refusal where measures would conflict with domestic law or practice, information is unobtainable, or disclosure would reveal trade secrets or offend public policy, but bank or fiduciary status does not alone justify nondisclosure. States shall use their information gathering measures to obtain requested information and may allow authorized representatives to interview individuals, examine records, or attend tax examinations under notified procedures.

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