ARTICLE 25
Exchange of Information
(1) The competent authorities of the Contracting States shall exchange such information as is necessary to apply the provisions of this Convention and of the domestic laws of the Contracting States concerning taxes covered by this Convention insofar as the taxation thereunder is not contrary to this Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons or authorities other than those concerned with the assessment or collection of the taxes covered by this Convention.
(2) In no case shall the provisions of paragraph (1) be construed so as to impose upon a Contracting State the obligation:
- (a) to take administrative measures at variance with the laws and administrative practices of either of the Contracting States;
- (b) to supply information that is prohibited under the laws or in the normal course of administration of either of the Contracting States;
- (c) to supply information that 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 (order public).