Exchange of information enables cross-border tax cooperation while safeguarding secrecy and limiting disclosure obligations under domestic law.

Article 26 provides for exchange of tax-related information, including documents, as necessary to implement the Convention and domestic tax laws for prevention of fraud or evasion; such information must be treated as secret and disclosed only to persons or authorities involved in assessment, collection, enforcement, prosecution, or appeals and used solely for those purposes, subject to permitted disclosure in public court proceedings. The provision exempts States from obligations that conflict with their laws or practices, from supplying unobtainable information, and from disclosing trade or professional secrets or information contrary to public policy.

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