ARTICLE 24. EXCHANGE OF INFORMATION

This Article provides for a system of administrative cooperation between the competent authorities of the two States and specifies conditions under which in­ formation may be exchanged to facilitate the administration of the Convention and to prevent fraud and the avoidance of taxes to which the Convention relates.

Information exchanged is treated as secret and may not be disclosed to any persons other than those (including a court or administrative body) concerned with the assessment, collection, enforcenwnt, or prosecution of taxes subject to the Convention, but this does not prohibit disclosure In the course of a court proceeding. In no case does this Article impose an obligation on either State to exchange information which would disclose trade secrets or similar information.

Further, information shall not be exchanged unless that Information Is available to a Contracting State under its taxation laws and administrative procedures.

The mutual exchange of Information called for by these provisions is presently In effect in most of the conventions to which the United States Is a party.