Exchange of information: amended tax treaty requires broad information sharing with confidentiality and data protection safeguards. The Protocol replaces Article 26 to require the competent authorities to exchange foreseeably relevant information for administration or enforcement of domestic taxes, subject to confidentiality and use limits; information received must be treated as secret and disclosed only to designated persons or authorities for tax assessment, collection, enforcement, prosecution, appeal determination or oversight, with other uses permitted only where both States' laws allow and the supplying State authorises; a requested State must use its information gathering measures even if it has no domestic interest; bank or fiduciary secrecy alone cannot justify refusal; agencies must protect personal data against unauthorized access, alteration and disclosure.