Exchange of information enables cross-border tax data sharing, subject to confidentiality, limited exceptions, and prohibition of bank secrecy refusals.

Competent authorities must exchange information, including documents, that is foreseeably relevant to administering or enforcing domestic tax laws or the Convention; such information must be kept secret and disclosed only to persons or authorities concerned with tax assessment, collection, enforcement, prosecution, appeals or oversight and used only for those purposes unless both States' laws and the supplying State authorize broader use. A State need not act contrary to its laws, supply unobtainable information, or disclose protected trade secrets or information contrary to public policy, but must use its information-gathering measures to obtain requested information and may not refuse solely because the information is held by banks, fiduciaries, nominees, or relates to ownership interests.

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