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 covered by this Convention insofar as the taxation thereunder is not contrary to this Convention. The exchange of information shall not be 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 and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of the taxes covered by this Convention, the enforcement or prosecution in respect of these taxes, or the determination of appeals in relation to these taxes. Such persons or authorities shall use the said information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
(2) In no case shall the provisions of paragraph (1) of this Article, be construed so as to impose on a Contracting State the obligation:
- (a) to carry out administrative measures which are at variance with the laws and administrative practice 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 which would disclose any trade, business, industrial, professional secret or trade process, or information, the disclosure of which would be contrary to public policy.