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

LIMITATION ON BENEFITS

1. It is understood that the provisions of the Convention shall not be interpreted so

as to prevent the application by a Contracting State of the anti-avoidance provisions

provided for in its domestic law.

2. It is understood that the benefits foreseen in the Convention shall not be granted

to a resident of a Contracting State which is not the beneficial owner of the income

derived from the other Contracting State.

3. The provisions of the Convention shall not apply if it was the main purpose or

one of the main purposes of any person concerned with the creation or assignment of

the property or right in respect of which the income is paid to take advantage of those

provisions by means of such creation or assignment.

4. Notwithstanding that a person would otherwise qualify for the benefits of the

Convention under the preceding paragraphs of this Article, a person that is entitled to

income tax benefits under the provisions of:

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