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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Thailand: double taxation agreement, Article 26: Exchange of information

(1) The competent authorities of the Contracting States shall exchange such informationas is necessary for the carrying out of this Convention or for the prevention of fraud orfor the administration of the domestic laws of the Contracting States concerning taxescovered by this Convention insofar as the taxation thereunder is in accordance with thisConvention. Any information so exchanged shall be treated as secret and shall not bedisclosed to any persons other than persons (including a Court or administrative body)concerned with the assessment or collection of, or prosecution in respect of, or thedetermination of appeals in relation to, the taxes which are the subject of theConvention.

(2) In no case shall the provisions of paragraph (1) of this Article be construed so as toimpose on the competent authority of either Contracting State the obligation:

(a) to carry out administrative measures at variance with the laws or administrative practice prevailing in either Contracting State;
(b) to supply particulars which are not obtainable under the laws or in the normal course of the administration of that or the other Contracting State;
(c) to supply information which would disclose any business, trade, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy.