[62 STAT. Exchange of Ifor- mation. Collection of taxes etc. Request for Infor- atinu or as-aitane. AmXCLE XXI The competent authorities of the Contracting States shall ex- change such information (being information which such authorities have in proper order at their disposal) as is necessary for carrying out the provisions of the present Convention or for the prevention of fraud or the administration of statutory provisions against legal avoidance in relation to the taxes which are the subject of the present Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any person other than those concerned with the assessment and collection of the taxes which are the subject of the present Convention. No information as aforesaid shall be exchanged which would disclose any trade, business, industrial or professional secret or trade process. ARTaCLE XXII (1) The Contracting States undertake to lend assistance and sup- port to each other in the collection of the taxes which are the subject of the present Convention, together with interest, costs, and additions to the taxes and fines not being of a penal character. (2) In the case of applications for enforcement of taxes, revenue claims of each of the Contracting States which have been finally determined may be accepted for enforcement by the other Contract- ing State and collected in that State in accordance with the laws applicable to the enforcement and collection of its own taxes. The State to which application is made shall not be required to enforce executory measures for which there is no provision in the law of the State making the application. (3) Any application shall be accompanied by documents estab- lishing that under the laws of the State making the application the taxes have been finally determined. (4) The assistance provided for in this Article shall not be accorded with respect to the citizens, corporations, or other entities of the State to which application is made, except as is necessary to insure that the exemption or reduced rate of tax granted under the conven- tion to such citizens, corporations or other entities shall not be enjoyed by persons not entitled to such benefits. ARTICLE XXIII (1) In no case shall the provisions of Article XXI and XXII be construed so as to impose upon either of the Contracting States the obligation (a) to carry out administrative measures at variance with the regulations and practice of either Contracting State, or (b) to supply particulars which are not procurable under its own legislation or that of the State making application. (2) The State to which application is made for information or assistance shall comply as soon as possible with the request addressed 1766 TREATIES
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