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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 28

Exchange of Information

(1) The competent authorities of the Contracting States shall exchange such information as is necessary for enforcing the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention, insofar as the taxation there under does not contradict with the Convention. The exchange of information is not restricted by Article (1) of this Convention. Any information received by a Contracting State shall be treated as confidential in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to the taxes covered under the Convention. Such persons or authorities shall use the said information only for such purposes. They may disclose the information in public court proceedings or on passing judgments.

(2) In no case shall the provisions of paragraph (1) of this Article be construed as imposing on a Contracting State an obligation:

  • (a) to take administrative measures in conflict with the laws and administrative practice of that or the other Contracting State;
  • (b) to provide information, which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
  • (c) to provide information which would disclose any trade, business, industrial, commercial or professional secrets or trade process, or information, the disclosure of which would be contrary to public order.