Exchange Information. 1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement for the prevention or detection of evasion or avoidance of taxes covered by this Agreement. Any information so exchanged shall be treated as secret and shall be disclosed only to any persons or authorities (including a Court or reviewing authority) concerned with the assessment, collection, enforcement or prosecution in respect of, or the determination of appeals in relation to the taxes which are the subject of this Agreement. 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 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws or the administrative practice of that or of the other State; (b) to supply particulars which are not obtainable under the laws or in the normal course of the administration of that or of the other State; (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret, trade process or information the disclosure of which would be contrary to public policy.
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Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation