Exchange of information requires cross-border tax data sharing while protecting confidentiality with specified legal limitations.

The competent authorities must exchange necessary tax information and documents for treaty implementation and fraud prevention, treating received information as secret and limiting disclosure to persons or authorities involved in assessment, collection, enforcement, prosecution or appeals; such use is restricted to those purposes though public court disclosure is permitted. Exchange may be routine or on request, with agreed routine lists. A State need not act contrary to its laws, supply unobtainable information, or disclose trade or professional secrets or information contrary to public policy, but must use its information gathering powers to obtain requested information and cannot refuse solely because it is held by banks, financial institutions, nominees or fiduciaries or relates to ownership interests.

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