Exchange of information: tax authorities may share necessary taxpayer information subject to secrecy and limited exceptions.

The competent authorities shall exchange information (including documents or certified copies) necessary to carry out the Agreement and domestic tax laws; such information must be treated as secret and disclosed only to persons or authorities concerned with assessment, collection, enforcement, prosecution, or appeals, and used solely for those purposes, though disclosure in public court proceedings or judicial decisions is permitted. A State is not obliged to act contrary to its laws or practice, provide information not obtainable under law or administration, or supply trade secrets or information contrary to public policy.

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