Exchange of information obligations enable cross-border tax data sharing while protecting confidentiality and limiting disclosure.

The Article requires the competent authorities of the Contracting States to exchange information necessary to implement the Convention and domestic tax laws, including for prevention of fraud, evasion and where appropriate avoidance, with received information treated as secret and, if secret in the transmitting State, disclosed only to persons or authorities involved in assessment, collection, enforcement, prosecution or appeals and used solely for those purposes except in public court proceedings. It also limits obligations to refrain from measures contrary to domestic law or practice, from supplying unobtainable information, and from disclosing trade or public policy sensitive information, and mandates consultation to set exchange procedures.

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