Tax information exchange requires cooperation despite no domestic interest, while preserving confidentiality and defined disclosure safeguards.

Article 26 establishes a tax-information exchange framework requiring competent authorities to exchange foreseeably relevant information, documents and certified copies for treaty implementation and the administration or enforcement of domestic taxes. Information must be kept secret, subject to limited tax-administration disclosures and specified secondary use. A requested State must use its information-gathering measures despite having no domestic tax interest, while retaining safeguards for unavailable information, protected secrets and public policy. Bank-held information and ownership interests cannot be refused solely on those grounds.

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