Exchange of Information
(1) The competent authorities of the contracting states shall exchange the information that are necessary for execution of the provisions of the instant treaty and the local laws of the contracting states as concerns the taxes stipulated in this treaty and where levying taxes by virtue thereof conforms to the provisions of the instant treaty.
The information exchanged in such manner are deemed confidential and may not be divulged to any person or authority other than the authorized persons who are assigned with the task of allocation of taxes dealt with in this treaty or collection of such taxes including the determination of taxes through courts.
(2) The provisions of paragraph (1) may not at all be interpreted as obligating a contracting state to do the following:
- (a) implementation of administrative procedures that are contrary to the laws or administrative regulations applicable therein or in the other contracting state.
- (b) providing data that are not accessible in accordance with the laws or administrative regulations that are customary therein or in the other contracting state.
- (c) providing data which are likely to reveal secrets pertinent to trade, industry, commercial or professional activity or commercial methods or information whose divulgence is deemed contrary to public order.