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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.

ARTICLE 26

Exchange of Information

(1) The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes of every kind and description as requested by the Contracting States, one of its political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to this Convention. The exchange of information shall not be limited by the provisions of Article 1 and Article 2 of this Convention. 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, and shall be disclosed only to persons or authorities (including courts and administrative bodies) in charge of the management or collection of taxes included in the first sentence, of the declaratory, or executive proceedings in relation to the said taxes or of the resolution of resources relating to the same. Such persons or authorities shall use the information only for these purposes. They may disclose the information in public court proceedings or in judicial decisions.

(2) In no case shall the provisions of paragraph (1) be construed so as to impose on 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 other Contracting State;
  • (c) to supply information that would disclose any trade, industrial, commercial or professional secrets or trade process, or information the disclosure of which would be contrary to public policy (ordre public).