ARTICLE 25
Exchange of Information
(1) The competent authorities of the Contracting States shall, upon request, exchange such information (being information available under the respective taxation laws of the Contracting State) as is necessary for carrying out, the provisions of this Agreement. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons other than those concerned with the assessment and collection of the taxes which are the subject of this Agreement. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or any trade process.
(2) In no case shall the provisions of paragraph (1) be construed so as to impose upon either of the Contracting States the obligation to carry out administrative measures at variance with the regulations and practice of either Contracting State or which would be contrary to its sovereignty, security or public policy or to supply particulars which are not procurable under the legislation of either State.