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HMRC internal manual

Double Taxation Relief Manual

DT: Philippines: double taxation agreement, Article 24: Exchange of information

(1) The competent authorities of the Contracting States shall exchange such informationas is necessary for the carrying out of the provisions of this Convention and of thedomestic laws of the Contracting States concerning taxes covered by this Convention, inparticular, for the prevention of fraud or evasion of such taxes. Any information soexchanged shall be treated as secret, but may be disclosed to persons (including a courtor administrative body) concerned with the assessment, collection, enforcement orprosecution in respect of the taxes which are the subject of the Convention.

(2) In no case shall the provisions of paragraph (1) be construed so as to impose on oneof the Contracting States the obligations:

  1. to carry out administrative measures at variance with the laws or the administrative practice of that or of the other Contracting State;

  2. to supply particulars which are not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;

  3. to supply information which 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.