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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 27

Exchange of Information

(1) The competent authorities of both Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention, preventing or unveiling tax evasion. Any information exchanged shall be treated as confidential in accordance with the domestic legislations and shall not be disclosed to any person or authority (including administrative authorities and courts) other than those concerned with the assessment, collection or litigation on taxes included herein as well as persons connected to these information.

(2) Information may be exchanged upon an application in specific cases.

(3) In no case shall the provisions of paragraph (1) of this Article be construed so as to impose upon a Contracting State the obligation to:

  • (a) take administrative measures contrary to the legislation or administrative practice of either of the Contracting States;
  • (b) provide information which is prohibited to be derived in accordance with the legislation or in the normal course of administrative practice of either of the Contracting States;
  • (c) provide information that would disclose any trade, economic, industrial, scientific, commercial or professional secrets as well as trade, professional or scientific transactions or information which shall not be disclosed according to the policy of the "general law".