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 26
Exchange of Information
(1) The competent authorities of the Contracting States shall exchange such information as is necessary for the application of this Convention. Any information so exchanged shall be treated as secret and may be disclosed only to persons, authorities or courts involved in the assessment or collection of the taxes which are the subject of this Convention, or in the consideration of administrative and judicial appeals or the prosecution of offences in respect of the said taxes. This does not apply to the disclosure of such information in open sessions of the competent courts.
(2) In no case shall the provisions of paragraph (1) be construed so as to impose on a Contracting State the obligation:
- (a) To carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
- (b) To supply information which is not obtainable under the laws or the normal administrative practice of that or of the other Contracting State;
- (c) To supply information which would disclose any trade, industrial, business or professional secret or trade or industrial process or information whose disclosure would be contrary to public policy.