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ARTICLE 26

U.S. Income Tax Treaty — belgium tax treaty documents: belgtech.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Exchange of Information

This Article provides for a system of administrative cooperation between the competent authorities of the two States and specifies conditions under which information may be exchanged to facilitate the administration of the Convention and to prevent fraud and the avoidance of taxes to which the Convention relates.

Information exchanged is treated as secret and may not be disclosed to any persons other than those (including a court or administrative body ) concerned with the assessment, collection, enforcement, or prosecution of taxes subject to the Convention, but this does not prohibit disclosure in the course of a court proceeding. In no case does this Article impose an obligation on either state to disclose trade secrets or similar information or to carry out administrative measures or supply particulars where such action would be at variance with the laws or administrative practice of that State, or contrary to public policy. In general, the standard for the exchange of information is the standard used by the States in the enforcement of their own laws by administrative and judicial authorities.

The mutual exchange of information called for by these provision is presently in effect in most of the conventions to which the United States is a party and is substantially similar to the provision contained in the existing Convention.

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