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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.


Exchange of Information

(1) The competent authorities of the Contracting States shall exchange such information as is necessary for the carrying out of this Convention. Any information so exchanged shall be treated as secret and shall be disclosed only to persons or authorities bound to professional secrecy who are concerned with the assessment or collection of the taxes which are the subject of the Convention and with appeals relating thereto, and to the judicial authorities if necessary for the purpose of criminal prosecution in respect of such taxes.

The above-mentioned persons and authorities may reveal such information in public court proceedings or in judicial decisions.

(2) The provisions of paragraph (1) above may not, under any circumstances, be interpreted as imposing on one of the Contracting States, the obligation to:

  • (a) Take administrative measures derogating from its administrative practice or that of the other Contracting State;
  • (b) Provide information which could not be obtained on the basis of its own laws or within the framework of its usual administrative practice or those of the other Contracting State;
  • (c) Transmit information which would reveal secrets of a commercial, industrial or professional nature, or a trade process or information which would be contrary to public order.