for such purposes. They may disclose the information in public court proceedings or in

judicial decisions.

3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose

on a Contracting State the obligation:

a) to carry out administrative measures at variance with the laws and

administrative practice of that or of the other Contracting State;

b) to supply information which is not obtainable under the laws or in the normal

course of the administration of that or of the other Contracting State;

c) 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 (ordre public).

4. If information is requested by a Contracting State in accordance with this Article,

the other Contracting State shall use its information gathering measures to obtain the

requested information, even though that other State may not need such information for its

own tax purposes. The obligation contained in the preceding sentence is subject to the

limitations of paragraph 3 but in no case shall such limitations be construed to permit a

Contracting State to decline to supply information solely because it has no domestic

interest in such information.

5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting

State to decline to supply information solely because the information is held by a bank,

other financial institution, nominee or person acting in an agency or a fiduciary capacity or

because it relates to ownership interests in a person.

6. The Contracting States shall comply with the Guidelines for the Regulation of

Computer Files containing Personal Data as established by the United Nations General

Assembly Resolution A/RES/45/95, adopted on the 14th December 1990.

ARTICLE 27

MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS

Nothing in this Convention shall affect the fiscal privileges of members of

diplomatic missions or consular posts under the general rules of international law or under

the provisions of special agreements.

ARTICLE 28

LIMITATION OF BENEFITS

1. A person that is a resident of a Contracting State and derives income from the other

Contracting State shall not be entitled to relief from taxation otherwise provided for in this

Convention if it was the main purpose or one of the main purposes of any person

concerned with the creation or assignment of such item of income to take advantage of the

provisions of this Convention.

2. The provisions of this Convention shall not be applicable to companies which

benefit from a special fiscal treatment under the laws or administrative practice of that or

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