Exchange of Information
(1) The competent authorities of the Contracting States shall exchange, to the extent permitted by their domestic laws, such information (including documents) as is necessary for carrying out the provisions of this Agreement or of the domestic laws of the Contracting States concerning taxes covered by the Agreement, insofar as the taxation thereunder is not contrary to the Agreement, in particular for the prevention of fraud or evasion of such taxes. Any information received by a Contracting State shall be treated as confidential in the same manner as information obtained under the domestic laws of that State. However, if the information is originally regarded as confidential in the transmitting State, it shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes which are subject of the Agreement. Such persons or authorities shall use the information only for such purposes but may disclose the information in public court proceedings or in judicial decisions. The exchange of information or documents shall also be on request with reference to particular cases.
(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 or 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 the other Contracting State;
- (c) to supply information which would disclose any trade, industrial, commercial or professional secret or trade process or information the disclosure of which would be contrary to the interests of the first-mentioned State.
(3) The competent authorities of the Contracting States shall notify each other of the changes which are made in their tax laws.