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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.


Exchange of Information

(1) The competent authorities of the Contracting State shall exchange such information as is necessary to prevent tax evasion or fraud and to carry out the provisions of this Convention or of the domestic laws of the Contracting States relating to 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 Article 1 of this Convention. 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 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 this information only for these purposes and they may disclose this information in public court proceedings or in judicial decisions.

(2) In no case shall the provisions of paragraph (1) be construed as imposing on a Contracting State the obligation:

  • (a) to carry out administrative measures at variance with the laws and administrative practices of either one of the Contracting States;
  • (b) to supply information that is not obtainable under the laws or in the normal course of administration of either one of the Contracting States;
  • (c) to supply information that would disclose any business, industrial, or professional secret or trade processes or information, the disclosure of which would be contrary to public policy.