Exchange of Information
(1) The competent authorities of the Contracting States shall exchange such information as is necessary to prevent tax evasion and to apply the provisions of this Convention or 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 limited by the provisions of Article 1. 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) concerned with the assessment or collection of the taxes covered by this Convention, the enforcement or prosecution in respect of such taxes, or the determination of appeals in relation to them. Such persons or authorities shall use the 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 as imposing 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.
(3) The exchange of information shall take place upon request covering concrete, official or spontaneous cases.