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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 carrying out the provision of this Agreement or for the prevention of fiscal fraud. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons, authorities, or courts other than those concerned with the assessment, collection or prosecution in respect of taxes which are the subject of this Agreement.

(2) In no case shall the provisions of paragraph (1) be construed so as to impose on one of the Contracting States the obligation:

  • (a) to carry out administrative measures at variance with the laws, or the administrative practice of that or of the other Contracting State;
  • (b) to supply particulars which are 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 trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy.