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 27
Exchange of Information
(1) The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement. Any information so exchanged shall be treated as secret and shall be disclosed only to persons or authorities involved in the assessment or collection of the taxes covered by the Agreement.
(2) In no case shall the provisions of paragraph (1) be construed so as to impose on the competent authority of one of the Contracting States 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 in the normal course of the administration of that or of the other Contracting State;
- (c) to supply information which would disclose any business or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public), and, in the case of the Federal Republic of Germany, the obligation to supply information which would disclose any trade, industrial or commercial secret.