Exchange of information mandates cross-border tax data sharing with confidentiality, limited exceptions and active information-gathering obligations.

Competent authorities must exchange information foreseeably relevant for implementing the Agreement and for tax administration or enforcement; exchanged information is secret and may be 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 authority permit other uses. A State need not contravene its laws or administrative practice, supply unobtainable information, or disclose trade secrets or information contrary to public policy; however, information held by banks, financial institutions, nominees, agents or fiduciaries, or relating to ownership interests, cannot be refused solely on that ground.

---

---

---