МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

Article 26
                       Exchange of information

     1.  The  competent  authorities  of  the Contracting States shall
exchange  such  information  as  is  necessary  for  carrying  out the
provision   of  this  Convention  or  of  the  domestic  laws  of  the
Contracting  States concerning taxes covered by the Convention insofar
as  the  taxation  thereunder  is  not  contrary to the Convention, in
particular  for  the prevention of fraud or evasion of such taxes. The
exchange  of  information  is  not restricted by Articles 1 and 2. Any
information  received  by  a  Contracting  State  shall  be treated as
confidential  in  the  same  manner  as information obtained under the
domestic  laws of that State and shall be disclosed only to persons or
authorities  (including  courts and administrative bodies) involved in
the  assessment  or  collection  of, the enforcement or prosecution in
respect  of, or the determination of appeals in relation to, the taxes
covered  by  the Convention. Such persons or authorities shall use the
information  only for such purposes. They may disclose the information
in  public  court  proceedings or in judicial decisions. The competent
authorities may, through consultation, develop appropriate conditions,
methods and techniques concerning the matters in respect of which such
exchanges  of information shall be made, including, where appropriate,
exchanges of information regarding tax avoidance.
     2. In no case shall the provisions of paragraph 1 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.