Exchange of Information
(1) The competent authorities of the Contracting States shall exchange such information as necessary to implement the provisions of this Agreement, or the law of the Contracting States concerning taxes covered by this Agreement, provided that the imposition purpose not contrary to the Agreement. The exchange of information is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State. However, if the information is originally regarded as secret in the transmitting State, it shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of taxes mentioned above, for the prosecution of crimes or the determination of appeals in relation to taxes Agreement Such persons or authorities shall use the information only for tax purposes. They must disclose the information in court or judicial decisions.
(2) In no case shall the provisions of paragraph (1) be construed as obliging a Contracting State to: