20/1995

Yleissopimus veroasioissa annettavasta keskinäisestä virka-avusta

Konvention om ömsesidig handräckning i skatteärenden

Convention on mutual administrative assistance in tax matters

Perustiedot

Sopimustyyppi:
II Monenväliset sopimukset
6. Valtio
6.1. julkishallinto
Allekirjoituspäivä:

25.01.1988 (Strasbourg)

Ratifiointipäivä:15.12.1994 H
Voimaantulopäivä:01.04.1995
Kansainvälinen voimaantulopäivä: 01.04.1995
Sopimukset: 20/1995 21/1995
Säädösviitteet: 358/1995 359/1995

Sopimukseen tehdyt muutokset

  • 30/2017 30/2017, 14/2018 14/201827.1.2016Monenkeskinen toimivaltaisten viranomaisten sopimus maakohtaisten raporttien vaihtamisesta
  • 39/2011 39/2011, 40/2011 40/201127.5.2010Pöytäkirja yleissopimuksen muuttamisesta
  • 57/199513.9.1995Selitys niistä yleissopimuksen 2 artiklan 1 kohdassa luetelluista veroista,joista Suomessa tällä hetkellä kannetaan veroja ja maksuja

Osapuolet

  • ALANKOMAAT
    Sitoutumispäivä: 15.10.1996 H
    Voimaantulopäivä: 01.02.1997
    Varauma:

    In conformity with the provisions of Article 29, paragraph 1, of the Convention, the Kingdom of the Netherlands accepts the said Convention for the Kingdom in Europe, the Netherlands Antilles and Aruba, subject to the following reservations.

    The Kingdom of the Netherlands (for the Netherlands and Aruba) declares in accordance with Article 30, paragraph 1, (a), (b), (c) and (d) of the Convention that it reserves the right:

    - not to provide assistance in relation to the taxes of other Parties listed in Article 2, paragraph 1, (b), (i), (iii), letters B, D, E, F and G, and (iv);

    - not to provide assistance in respect of any tax claim which is in existence on the date of entry into force of the Convention for the Kingdom of the Netherlands (for the Netherlands);

    - not to provide assistance in the service of documents for all taxes.

    The Kingdom of the Netherlands (for the Netherlands Antilles) declares in accordance with Article 30, paragraph 1 (a), (b), (c) and (d) of the Convention, that it reserves the right:

    - not to provide assistance in relation to the taxes of other Parties listed in Article 2, paragraph 1, (b);

    - not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes;

    - not to provide assistance in respect of any tax claim which is in existence on the date of entry into force of the Convention for the Kingdom of the Netherlands (for the Netherlands Antilles and Aruba);

    - not to provide assistance in the service of documents for all taxes;

    - not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.

    The Kingdom of the Netherlands (for the Netherlands) declares, in accordance with Article 4, paragraph 3, that its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7.

    The Kingdom of the Netherlands (for the Netherlands) declares, in accordance with Article 9, paragraph 3, that it will not accept, as a general rule, the requests as referred to in Article 9, paragraph 1, of the Convention, insofar as these requests concern social security contributions.

    The Kingdom of the Netherlands (for the Netherlands Antilles and Aruba) declares, in accordance with Article 4, paragraph 3, that authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7.

    The Kingdom of the Netherlands (for the Netherlands Antilles and Aruba) declares, in accordance with Article 9, paragraph 3, that it will not accept, as a general rule, the requests as referred to in Article 9, paragraph 1, of the Convention.

    Article 30, paragraph 2, of the Convention prohibits other reservations than those explicitly allowed under paragraph 1 of Article 30. In the present context, this means that all reservations further limiting the application of provisions of the Convention are prohibited. The declaration made in respect to the Netherlands Antilles and Aruba, however, is of a different nature as it refers to territorial application and does not, in the view of the Netherlands Government, constitute a reservation prohibited under Article 30 of the Convention. The Netherlands Antilles and Aruba will observe the Convention in relation to those Parties to the Convention with which a convention for the avoidance of double taxation has been concluded.
    The Kingdom of the Netherlands will apply the Convention to the Netherlands Antilles and Aruba only in respect of Parties to this Convention with which the Kingdom of the Netherlands has concluded a convention for the avoidance of double taxation which is applicable to the Netherlands Antilles and/or Aruba and which contains a provision concerning exchange of information.

    ANNEX A

    Taxes to which the Convention applies for the Netherlands:

    Article 2, paragraph 1 (a)

    - Income Tax (Inkomstenbelasting)
    - Salaries Tax (Loonbelasting)
    - Corporation Tax (Vennootschapsbelasting)
    - Dividend Tax (Dividendbelasting)
    - Wealth Tax (Vermogensbelasting)

    Article 2, paragraph 1 (b)

    - Social Security Contributions (Premies sociale verzekering)

    Article 2, paragraph 1 (c)

    - Inheritance, Transfer or Gift Tax (Rechten van successie, overgang of schenking)

    ANNEX A

    Taxes to which the Convention applies for the Netherlands Antilles:

    Article 2, paragraph 1 (a)

    - Income Tax (Inkomstenbelasting)
    - Salaries Tax (Loonbelasting)
    - Corporation Tax (Winstbelasting)

    ANNEX B

    Taxes to which the Convention applies for Aruba :

    Article 2, paragraph 1 (a)

    - Income Tax (Inkomstenbelasting)
    - Salaries Tax (Loonbelasting)
    - Corporation Tax (Winstbelasting)

    ANNEX B

    Competent Authorities for the Netherlands:

    - For tax purposes : the Minister of Finance or his authorised representative;
    - For Social security purposes: the State Secretary for Social Affairs and Employment or his authorised representative.

    ANNEX B

    Competent Authorities for the Netherlands Antilles:

    - the Minister of Finance or his authorised representative.

    ANNEX B

    Competent Authorities for Aruba:

    - the Minister of Finance or his authorised representative.

    ANNEX C - Definition of the term "national" for the purpose of the Convention:

    The term "national" means for the Netherlands:

    1. all individuals possessing the Dutch nationality;
    2. all legal persons, companies and associations deriving their status as such from the laws in force in the Netherlands.

    ANNEX C - Definition of the term "national" for the purpose of the Convention:

    The term "national" means for the Netherlands Antilles:

    1. all individuals possessing the Dutch nationality;
    2. all legal persons, companies and associations deriving their status as such from the laws in force in the Netherlands Antilles.

    ANNEX C - Definition of the term "national" for the purpose of the Convention:

    The term "national" means for Aruba:

    1. all individuals possessing the Dutch nationality and having a legally valid title of residence for Aruba;
    2. all legal persons, companies and associations deriving their status as such from the laws in force in Aruba.


    Withdrawal of a reservation contained in a letter from the Permanent Representative of the Netherlands, dated 18 July 2001, registered at the Secretariat General on 19 July 2001 - Or. Engl.

    The Kingdom of the Netherlands, for the Kingdom in Europe and Aruba, withdraws the reservation with regard to the category listed in Article 2, paragraph 1, subparagraph (b), (iii), under letter C, of the Convention, made at the time of deposit of its instrument of acceptance on 15 October 1996. This means that the said reservation will last with regard to the Netherlands Antilles.

    _____
    Note by the Secretariat : The reservation now reads as follows :

    "The Kingdom of the Netherlands (for the Netherlands and Aruba) declares in accordance with Article 30, paragraph 1, (a), (b), (c) and (d) of the Convention, that it reserves the right :

    - not to provide assistance in relation to the taxes of other Parties listed in Article 2, paragraph 1,(b), (i), (iii), letters B, D, E, F and G, and (iv);

    (.)
    The Kingdom of the Netherlands (for the Netherlands Antilles) declares in accordance with Article 30, paragraph 1, (a), (b), (c) and (d) of the Convention, that it reserves the right :

    - not to provide assistance in relation to the taxes of other Parties listed in Article 2, paragraph 1,(b), (i), (iii), letter C."

    NETHERLANDS

    Declaration transmitted by a Note Verbale from the Permanent Mission of the Kingdom of the
    Netherlands to the OECD, dated 31 May 2020, registered at the Secretariat General
    of the OECD on 5 August 2020

    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority
    Agreement on the Exchange of Country-by-Country reports.
    The Permanent Mission of the Kingdom of the Netherlands to the Organisation for Economic Cooperation and Development has the honor to refer to the underneath declaration for the Kingdom of the Netherlands, on behalf of Aruba, concerning the Convention on Mutual Administrative Assistance in
    Tax Matters. This declaration is in accordance with the provisions of Article 32 of the Agreement.
    Considering that Aruba intends to start automatically exchanging Country by Country Reports (hereafter
    the ???CbC MCAA???) as of 2020 and that, in order to be able to automatically exchange such information
    under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the
    Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters (hereafter the
    ???amended Convention???), Aruba has signed a Declaration on joining the Multilateral Competent Authority
    Agreement on the Exchange of Country-by-Country reports on 12 March 2020;
    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for
    administrative assistance related to taxable periods beginning on or after 1 January of the year following
    the one in which the amended Convention entered into force in respect of a Party, or where there is no
    taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the
    year following the one in which the amended Convention entered into force in respect of a Party;
    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may
    mutually agree that the amended Convention shall have effect for administrative assistance related to
    earlier taxable periods or charges to tax;
    Mindful that information may only be sent by a jurisdiction under the amended Convention with respect
    to taxable periods or charges to tax of the receiving jurisdiction for which the amended Convention is in
    effect and that, as a consequence, sending jurisdictions for which the Convention has newly entered into
    force in a given year are only in a position to provide administrative assistance to receiving jurisdictions
    for taxable periods beginning or charges to tax arising on or after 1 January of the following year;
    Acknowledging that an existing Party to the amended Convention would be able to receive information
    under Article 6 of the amended Convention and the CbC MCAA from a new Party with respect to earlier
    taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties
    declare to agree that another date of effect is applicable;

    Further acknowledging that, therefore, a new Party to the amended Convention would be able to send
    information under Article 6 of the amended Convention and the CbC MCAA to an existing Party with
    respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if
    both Parties declare to agree that another date of effect is applicable;
    Confirming that the capacity of a jurisdiction to send CbC Reports under Article 6 of the amended
    Convention and the CbC MCAA shall be governed by the terms of the CbC MCAA, including the relevant
    reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods or
    charges to tax of the receiving jurisdiction to which such information relates;
    The Kingdom of the Netherlands declares, for Aruba, that the amended Convention shall have effect in
    accordance with the terms of the CbC MCAA for administrative assistance under the CbC MCAA
    between Aruba and the other Parties to the amended Convention that have made similar declarations,
    irrespective of the taxable periods or charges to tax to which such information relates in the receiving
    jurisdiction.

  • ALBANIA
    Sitoutumispäivä: 08.08.2013 R
    Voimaantulopäivä: 01.12.2013
    Varauma:

    Articles 2, 30

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Albania reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b:

    iii. Taxes in other categories, except customs duties, imposed on behalf of a Party, namely:
    A. estate, inheritance or gift taxes,
    B. taxes on immovable property,
    F. taxes on the use or ownership of movable property other than motor vehicles.

    iv. Taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

    In accordance with Article 30, paragraph 1.b, of the Convention, the Republic of Albania reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for taxes described in Article 2, paragraph 1.b, of the Convention.

    In accordance with Article 30, paragraph 1.d, of the Convention, the Republic of Albania reserves the right not to provide assistance in the service of documents for the taxes described in Article 2, paragraph 1.b, of the Convention.

    In accordance with Article 30, paragraph 1.e, of the Convention, the Republic of Albania reserves the right not to permit the service of documents through the post as provided in Article 17, paragraph 3, with respect to the taxes described in Article 2, paragraph 1.b, of the Convention.

    Article 2

    ANNEX A ??? Existing taxes to which the Convention shall apply:

    Article 2, paragraph 1.a.i:
    - Personal Income Tax (Tatimi mbi te Ardhurat Personale)

    Article 2, paragraph 1.a.ii:
    - Corporate Income Tax (Tatim Fitimi)

    Article 2, paragraph 1.b.i:
    - Local Tax on Small Business (Taska Vendore mbi Biznesin e Vogel)

    Article 2, paragraph 1.b.ii:
    - Social Security Contributions (Kontributet e Sigurimeve Shoqerore)

    Article 2, paragraph 1.b.iii.C:
    - Value Added Tax (Tatimi mbi Vleren e Shtuar)

    Article 2, paragraph 1.b.iii.D:
    - Excise Duties (Akciza)

    Article 2, paragraph 1.b.iii.E:
    - Annual Tax on used motor Vehicles (Taska vjetore e mjeteve t?? p??rdorura)

    Article 2, paragraph 1.b.iii.G:
    - Local Tax on Real Estate (Tatimet mbi Pasurine e Paluajtshme)

    Article 3

    ANNEX B ??? Competent Authorities

    the Republic of Albania declares that the competent authority, with the powers mentioned in Article 3, paragraph 1.d., of the Convention, is the Ministry of Finance: General Tax Directory.

  • ANDORRA
    Sitoutumispäivä: 25.08.2016 R
    Voimaantulopäivä: 01.12.2016
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 25 August 2016

    In accordance with Article 30, paragraph 1.a, of the Convention, the Principality of Andorra will not provide any form of administrative assistance in relation to the taxes of other Parties referred to in Article 2, paragraph 1.b, of the Convention.
    In accordance with Article 30, paragraph 1.b, of the Convention, the Principality of Andorra will not provide any form of administrative assistance in the recovery of tax claims, or in the recovery of administrative fines, for all taxes listed in Article 2, paragraph 1, of the Convention.
    In accordance with Article 30, paragraph 1.c, of the Convention, the Principality of Andorra will not provide assistance in respect of any tax claim which was in existence at the date of entry into force of the Convention in respect of the Principality of Andorra.
    The Principality of Andorra will not provide assistance in respect of any tax claim which was in existence at the date of withdrawal of a reservation made under Article 30, paragraphs 1.a or 1.b, of the Convention.
    In accordance with Article 30, paragraph 1.d, of the Convention, the Principality of Andorra will not provide assistance in the service of documents for all taxes listed in Article 2, paragraph 1, of the Convention.
    In accordance with Article 30, paragraph 1.f, of the Convention, the Principality of Andorra declares that, for tax matters involving intentional conduct which is liable to prosecution under the criminal laws of the applicant Party the provisions of this Convention shall apply for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Principality of Andorra, or, where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Principality of Andorra.
    2
    In accordance with Article 4, paragraph 3, of the Convention, the Principality of Andorra may inform the persons concerned before transmitting information to a Party pursuant to Articles 5 and 7 of the Convention.
    In accordance with Article 9, paragraph 3, of the Convention, the Principality of Andorra declares that it will, as a general rule, not accept requests to allow representatives of the competent authority of the applicant State to be present at the appropriate part of a tax examination in the Principality of Andorra.
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i - Taxes on income or profits
    - Corporation tax;
    - Tax on income of individuals;
    - Income tax of economic activities;
    - Income tax on income of non-residents in Andorra
    Article 2, paragraph 1.a.ii - Taxes on capital gains which are imposed separately from the tax on income or profits
    - Tax on capital gain on real estate capital transfer.
    Article 2, paragraph 1.a.iii - Taxes on net wealth
    - None
    ANNEX B - Competent authorities
    In Andorra, the term "competent authority" means the Minister of Finance or his authorised representative.

  • ANTIGUA JA BARBUDA
    Sitoutumispäivä: 16.10.2018 R
    Voimaantulopäivä: 01.02.2019
    Varauma:

    Declarations

    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i:
    Income Tax
    Article 2, paragraph 1.a.ii:
    None
    Article 2, paragraph 1.a.iii:
    Income Tax
    Article 2, paragraph 1.b.i:
    Income Tax
    Article 2, paragraph 1.b.ii:
    Social Security Tax
    Article 2, paragraph 1.b.iii.A:
    Stamp Duty
    Article 2, paragraph 1.b.iii.B:
    Property Tax
    Article 2, paragraph 1.b.iii.C:
    Antigua and Barbuda Sales Tax
    Article 2, paragraph 1.b.iii.D:
    Customs Tax
    Article 2, paragraph 1.b.iii.E:
    Transport Board Tax
    Article 2, paragraph 1.b.iii.F:
    Property Tax
    Article 2, paragraph 1.b.iii.G:

    ANNEX B ??? Competent Authorities
    The Commissioner of the Inland Revenue Department or his authorised representative.

    ANNEX C ??? Definition of the word "national" for the purpose of the Convention
    The term ???national??? in relation to Antigua and Barbuda means:
    i. all individuals possessing the nationality of Antigua and Barbuda, and
    ii. all legal persons, partnerships, associations and other entities deriving their status as such from the laws in force in Antigua and Barbuda.

  • ARABIEMIIRIKUNNAT
    Sitoutumispäivä: 21.04.2017 A
    Voimaantulopäivä: -
    Varauma:

    Pursuant to Article 30, paragraph 1.a, of the Convention, the United Arab Emirates reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the categories listed in Article 2, paragraph 1.b, of the Convention.

    Pursuant to Article 30, paragraph 1.b, of the Convention, the United Arab Emirates reserves the right not to provide assistance in the recovery of any tax claim, or the recovery of an administrative fine, for all taxes.

    Pursuant to Article 30, paragraph 1.c, of the Convention, the United Arab Emirates reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of the United Arab Emirates or, where a reservation has previously been made under sub-paragraph a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

    Pursuant to Article 30, paragraph 1.d, of the Convention, the United Arab Emirates reserves the right not to provide assistance in the service of documents for all taxes.

    Pursuant to Article 30, paragraph 1.f, of the Convention, the United Arab Emirates reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.

    Pursuant to Article 30, paragraph 1.f, of the Convention, the United Arab Emirates reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the United Arab Emirates, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the United Arab Emirates.

    In accordance with Article 4, paragraph 3, of the Convention, the United Arab Emirates declares that its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7 of the Convention.

    In accordance with Article 9, paragraph 3, of the Convention, the United Arab Emirates declares that it
    will not accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the
    Convention.
    3 / 4
    Article 29: the United Arab Emirates hereby declares that the term ???United Arab Emirates??? means the territory of the United Arab Emirates which is under its sovereignty as well as the area outside of the territorial water, airspace and submarine areas over which the United Arab Emirates exercises sovereign and jurisdictional rights in respect of any activity carried on in its water, sea bed, sub soil, in connection with the exploration for or the exploitation of natural resources by virtue of its law and
    international law.

    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i: Taxes on income and profit

    ANNEX B - Competent authorities
    The Ministry of Finance represented by the Minister of Finance or his authorized representative.

    ANNEX C - Definition of the term ???national??? for the purpose of the Convention
    The term ???national??? in relation to the United Arab Emirates means:
    - any individual possessing the citizenship of the United Arab Emirates; and
    - any legal person, partnership or association, instrumentalities and statutory bodies deriving its
    status as such from the laws in force in the United Arab Emirates.

  • ARGENTIINA
    Sitoutumispäivä: 13.09.2012 R
    Voimaantulopäivä: 01.01.2013
    Varauma:

    Article 2

    ANNEX A ??? Taxes to which the Convention would apply:

    Article 2, paragraph 1.a.i:
    Income Tax.

    Article 2, paragraph 1.b.ii:
    Contributions to Social Security.

    Article 2, paragraph 1.b.iii. A:
    Tax on Personal Property.

    Article 2, paragraph 1.b.iii. C:
    Value Added Tax.

    Article 2, paragraph 1.b.iii. D:
    Tax on Liquid Fuels,
    Domestic Tax, Law 24764,
    Tax on Insurance and other Assets, Law 3764.

    Article 2, paragraph 1.b.iii. G:
    Presumptive Income Tax,
    Real Property Transfer Tax,
    Tax on the Debits and Credits originated from Financial Transactions, Law 25413,
    Simpified Regime for Taxpayers (Monotributo).

    Article 30

    The Argentine Republic shall not provide any type of assistance in relation to the taxes of the other Parties as mentioned in Article 2, paragraph 1, sub-paragraphs b.i or b.iv, of the Convention according to Article 30, paragraph 1.a, of the Convention.

    The Argentine Republic shall not provide assistance in the collection of tax claims or in the collection of administrative fines, for all the taxes, according to the provisions of Articles 11 and 12 of the Convention.

    The Argentine Republic shall not provide assistance for the notification and the transfer of documents for any tax, according to the provisions of Article 17 of the Convention.

    Article 3

    ANNEX B ??? Competent Authorities

    The Argentine Republic declares that the competent authority, with the powers mentioned in Article 3, paragraph 1.d, of the Convention, is the Federal Administration of Public Revenue.

  • ARMENIA
    Sitoutumispäivä: 06.02.2020 R
    Voimaantulopäivä: 01.06.2020
    Varauma:

    ARMENIA
    Objection and declarations contained in the instrument of ratification deposited with the Secretary General of the Council of Europe on 6 February 2020

    Objection
    The Republic of Armenia objects to the declaration of the Republic of Azerbaijan dated 23 May 2014, registered at the Secretariat General of the OECD on 23 September 2014 and confirmed at the time of ratification of the Protocol on 29 May 2015, and to the declaration of the Republic of Turkey dated 19 October 2011, handed over to the Secretary General of the OECD on 3 November 2011 and confirmed in the instrument of ratification deposited with the Secretary General of the OECD on 26 March 2018, both limiting the implementation of the provisions of the Convention and Protocol only to the States with which the Republic of Azerbaijan and the Republic of Turkey have diplomatic relations.
    The aforementioned declarations, which attempt to modify or limit the rights and obligations under the Convention, constitute, in fact, reservations and neither fall under the scope or Article 30 of the Convention, nor are compatible with the object and purpose of the Convention to establish a framework for the cooperation between the member States of the Council of Europe, therefore, as such shall be considered null and void.
    Until the withdrawal of the aforementioned reservations, the Republic of Armenia declares that it will be unable to ensure the application of the Convention and Protocol in respect of the Republic of Azerbaijan and the Republic of Turkey.

    Declarations
    The Declaration of the Republic of Azerbaijan contained in the instrument of ratification deposited on 3 June 2004, includes unsubstantiated and baseless allegations against the Republic of Armenia and distorts the essence of the Nagorno-Karabakh conflict which was triggered and sustained by the use of force by Azerbaijan against peaceful demands of the people of Nagorno-Karabakh (Republic of Artsakh) for human rights and self-determination.

    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i:
    ??? Income Tax, Profit Tax
    Article 2, paragraph 1.b.iii.C:
    ??? Value-Added Tax
    Article 2, paragraph 1.b.iii.D:
    ??? Excise Tax
    Article 2, paragraph 1.b.iii.G:
    ??? Turnover Tax, Environmental Tax, Road Tax
    ANNEX B ??? Competent Authorities
    State Revenue Committee or its authorised representative.

  • AUSTRALIA
    Sitoutumispäivä: 30.08.2012 R
    Voimaantulopäivä: 01.12.2012
    Varauma:

    Article 2

    Annex A - Taxes to which the Convention applies

    For Australia, the Convention shall apply to taxes of every kind and description imposed under the federal laws of Australia administered by the Commissioner of Taxation which correspond to the taxes in the categories referred to in paragraphs 1(a) and (b)(ii) and (iii) of Article 2 of the Convention.

    Article 3

    Annex C - Definition of the term ???national??? for the purpose of the Convention

    In relation to Australia, the term ???national??? means any individual possessing the citizenship of Australia; and any legal person, company, partnership or association deriving its status as such from the laws in force in Australia.

    Annex B - Competent authorities

    In relation to Australia, the term ???competent authority??? means the Commissioner of Taxation or an authorised representative of the Commissioner.

    Article 29 - Territorial application of the Convention

    Pursuant to Article 29, paragraph 1, of the Convention, Australia declares that with respect to Australia, the Convention shall apply to Australia, excluding all external territories other than:

    (i) the Territory of Norfolk Island;
    (ii) the Territory of Christmas Island;
    (iii) the Territory of Cocos (Keeling) Islands;
    (iv) the Territory of Ashmore and Cartier Islands;
    (v) the Territory of Heard Island and McDonald Islands; and
    (vi) the Coral Sea Islands Territory,

    but including any area adjacent to the territorial limits of Australia (including the Territories specified in this Declaration) in respect of which there is for the time being in force, consistently with international law, a law of Australia dealing with the exploration for or exploitation of any of the natural ressources of the exclusive economic zone or the seabed or subsoil of the continental shelf.

  • AZERBAIDZHAN
    Sitoutumispäivä: 03.06.2004 R
    Voimaantulopäivä: 01.10.2004
    Varauma:

    The Republic of Azerbaijan declares that it will be unable to guarantee compliance with the provisions of the Convention in its territories occupied by the Republic of Armenia until these territories are liberated from that occupation.

    ANNEX A - Taxes to which the Convention would apply:

    Article 2, paragraph 1. a. i:
    . Income tax from individuals;
    . ?Profit tax from legal persons (with the exception of entities and enterprises that are the property of municipalities);
    . Tax whitheld at the source of payment on income of non-residents;
    . Tax withheld from the net profit of a permanent establishment.

    Article 2, paragraph 1. b. i:
    . Profit tax from entities and enterprises that are the property of municipalities.

    Article 2, paragraph 1. b. ii:
    . Payments to the State Social Protection Fund.

    Article 2, paragraph 1. b. iii.A:
    . Property tax from legal persons.

    Article 2, paragraph 1. b. iii.B:
    . Land tax from legal persons.

    Article 2, paragraph 1. b. iii.C:
    . Value added tax.

    Article 2, paragraph 1. b. iii.D:
    . Excise tax.

    Article 2, paragraph 1. b. iii.E:
    . Road tax.

    Article 2, paragraph 1. b. iii.G:
    . Mining tax;
    . Tax under simplified system;
    . Duties withheld according to the "Law of state duties".

    Article 2, paragraph 1. b. iv:
    . Land tax from individuals;
    . Property tax from individuals;
    . Mining tax on the exploitation of constructions materials produced in certain regions.

    ANNEX C - Definition of the term "national" is given in the following:

    The term "national" means:

    . all individuals possessing the nationality of the Republic of Azerbaijan;
    . all legal persons (including partnership and joint venture), companies, associations and other organisations deriving their status as such from the legislation of the Republic of Azerbaijan.

    ANNEX B - Competent authorities:

    Ministry of taxes, State Customs Committee, Ministry of Labour and Social Protection of Population, Ministry of Finance.

  • BAHAMA
    Sitoutumispäivä: 26.04.2018 R
    Voimaantulopäivä: 01.08.2018
  • BAHRAIN
    Sitoutumispäivä: 03.05.2018 R
    Voimaantulopäivä: 01.09.2018
  • BARBADOS
    Sitoutumispäivä: 04.07.2016 R
    Voimaantulopäivä: -
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016

    Pursuant to Article 30, paragraph 1.a, of the Convention, Barbados reserves the right not to provide any form of assistance in relation to the taxes of other Parties described in any of the categories listed in Article 2, paragraph 1.b., of the Convention.
    Pursuant to Article 30, paragraph 1.b, of the Convention, Barbados reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1.c, of the Convention, Barbados reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Barbados, or, if the tax claim is in relation to taxes which are listed in the reservation made under Article 30, paragraph 1. a or b of the Convention, at the date of withdrawal of such a reservation by Barbados.
    Pursuant to Article 30, paragraph 1.d, of the Convention, Barbados will not provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.e, of the Convention, Barbados reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.
    Pursuant to Article 30, paragraph 1.f, of the Convention, Barbados reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Barbados, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Barbados.
    Pursuant to Article 4, paragraph 3, of the Convention, Barbados may inform its resident or national before transmitting information to another party, in conformity with Article 5 and Article 7 of the Convention.
    Pursuant to Article 9, paragraph 3, of the Convention, Barbados will not accept, as a general rule, requests referred to in Article 9, paragraph 1, of the Convention.

    ANNEX A - Taxes to which the Convention would apply.
    Article 2, paragraph 1.a.i:
    Income tax
    Article 2, paragraph 1.a.ii:
    Corporation tax
    ANNEX B - Competent authorities
    The Barbados Revenue Authority.
    ANNEX C - Definition of the term "national" for the purpose of the Convention
    For the purposes of Article 3, paragraph 1.e, of the Convention, the term "national" in relation to Barbados means any individual possessing the nationality or citizenship of Barbados; and any legal person, partnership or association deriving its status as such from the laws in force in Barbados.

  • BELGIA
    Sitoutumispäivä: 01.08.2000
    Voimaantulopäivä: 01.12.2000
    Varauma:

    ANNEX A - Taxes to which the Convention would apply

    I. Article 2, ? 1.a.i:

    Personal tax,
    Corporation tax,
    Tax on legal persons,
    Tax on non-residents,
    Withholding tax on income from movable assets (tax on capital incomes), income tax deducted at source
    Special surcharge on tax on non-residents

    II. Article 2, ? 1.b.i:

    Special surcharge on personal tax,
    Withholding tax on income from immovable assets (property tax) and surcharge.

    III. Article 2, ? 1.b.iii:

    Under category A:

    Registration duties on gifts inter vivos.

    Under category C:

    Value added tax.

    Under category D:

    Excise duties,
    Special excise duties,
    Annual tax on insurance policies,
    Annual tax on profit sharing.

    IV. Article 2, ? 1.b.iv:

    Under category A:

    Death duties and duties on transfers following death.

    ANNEX B - Competent authorities

    Minister for Finance or an authorised representative.

    ANNEX C - Definition of the word "national" for the purpose of the Convention

    None.

    To Article 30, ? 1.a, of the Convention

    Belgium reserves the right not to provide any forms of assistance in relation to the taxes of other Parties in any of the categories listed in sub-paragraph b of paragraph 1 of Article 2:

    ii. : Compulsory social security contributions payable to general government or to social security institutions established under public law;
    iii. B : Taxes on immovable property;
    iii. E : Taxes on the use or ownership of motor-vehicles;
    iii. F : Taxes on the use or ownership of movable property other than motor-vehicles;
    iii. G : Any other taxes;
    iv. B : Taxes on immovable property;
    iv. C : General consumption taxes, such as value-added or sales taxes;
    iv. D : Specific taxes on goods and services such as excise duties;
    iv. E : Taxes on the use or ownership of motor-vehicles;
    iv. F : Taxes on the use or ownership of movable property other than motor-vehicles;
    iv. G : Any other taxes.

    To Article 30, ? 1.c, of the Convention

    Belgium reserves the right not to provide assistance in respect of any tax claim:

    - which is in existence at the date of entry into force of the Convention in respect of Belgium;
    - which was the subject of a reservation by Belgium based on Article 30, ? 1.a of the Convention and was already in existence at the date of withdrawal by Belgium of such a reservation.

  • BELIZE
    Sitoutumispäivä: 29.05.2013 R
    Voimaantulopäivä: 01.09.2013
    Varauma:

    Article 30

    In accordance with Article 30, paragraph 1.b, of the Convention, Belize reserves the right not to provide assistance in the recovery of any tax claim or in the recovery of administrative fine, for all taxes.

    In accordance with Article 30, paragraph 1.d, of the Convention, Belize reserves the right not to provide assistance in the service of documents for all taxes.

    Article 2

    Annex A ??? Taxes to which the Convention would apply:

    Article 2, paragraph 1.a.i:
    Income Tax (including surtax or surcharge)
    Business Tax

    Article 2, paragraph 1.b.iii. C:
    General Sales Tax.

    Article 3

    ANNEX B ??? Competent Authorities

    In relation to Belize, the term ???competent authority??? means the Financial Secretary in the Ministry of Finance.

    Article 3

    ANNEX C ??? Definition of the word "national" for the purpose of the Convention

    In relation to Belize, the term ???national??? means any individual possessing the citizenship of Belize.

    Article 29

    Pursuant to Article 29, paragraph 1, of the Convention, Belize declares that with respect to Belize, the Convention shall apply to the territory of Belize as defined in Schedule 1 to the Belize Constitution, including the territorial waters and any other area in the sea and in the air within which Belize, in accordance with international law, exercises sovereign rights or its jurisdiction.

  • BENIN
    Sitoutumispäivä: 27.11.2019 A
    Voimaantulopäivä: -
  • BOSNIA-HERTSEGOVINA
    Sitoutumispäivä: 21.09.2020 R
    Voimaantulopäivä: 01.01.2021
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the
    Secretariat General of the OECD on 21 September 2020

    In accordance with Article 30, paragraph 1, subparagraph a of the Convention, Bosnia and Herzegovina
    reserves the right not to provide any form of assistance with respect to the taxes of other parties in any
    of the following categories mentioned in subparagraph b, paragraph 1 of Article 2:
    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions
    or local authorities of a Party,
    ii. compulsory social security contributions payable to general government or to social security institutions
    established under public law,
    iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:
    A: estate, inheritance or gift taxes,
    B: taxes on immovable property,
    D: specific taxes on goods and services such as excise taxes,
    E: taxes on the use or ownership of motor vehicles,
    F: taxes on the use or ownership of movable property, other than motor vehicles,
    G: any other taxes,
    iv. taxes in categories referred to in subparagraph iii above which are imposed on behalf of political
    subdivisions or local authorities of a Party.
    In accordance with Article 30, paragraph 1, subparagraph b of the Convention, Bosnia and Herzegovina
    reserves the right not to provide assistance in the recovery of any tax claim or administrative fines, for
    taxes stated in the reservation made toward Article 30, paragraph 1, subparagraph a, of the Convention.
    In accordance with Article 30, paragraph 1, subparagraph c of the Convention, Bosnia and Herzegovina
    reserves the right not to provide assistance in relation to any tax claim existing at the date of entry into
    force of the Convention against Bosnia and Herzegovina, or if a tax claim relates to the taxes stated in
    the reservation made toward Article 30, paragraph 1, subparagraph a or b of the Convention, on the date
    of withdrawal of such reservation by Bosnia and Herzegovina.
    In accordance with Article 30, paragraph 1, subparagraph d of the Convention, Bosnia and Herzegovina
    reserves the right not to provide assistance with the submission of documents for the taxes specified in
    the reservation made toward Article 30, paragraph 1, subparagraph a of the Convention.
    In accordance with Article 30, paragraph 1, subparagraph f of the Convention, Bosnia and Herzegovina
    reserves the right to apply Article 28, paragraph 7, exclusively for administrative assistance relating to
    tax periods beginning on or after 1 January of the third year preceding that in which the Convention, as
    amended by the 2010 Protocol, entered into force with respect to Bosnia and Herzegovina, or in the
    absence of a tax period, for administrative assistance relating to tax liabilities incurred on or after I January
    of the third year preceding that in which the Convention, as amended by the 2010 Protocol, entered into
    force in respect of Bosnia and Herzegovina.

    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i:
    - Personal income tax
    - Corporate income tax
    Article 2, paragraph 1.b.iii.C:
    - Value Added Tax.
    ANNEX B ??? Competent Authorities
    For taxes referred to in Article 2, paragraph 1, subparagraph a.i., the competent authorities shall be as
    follows: the Federal Ministry of Finance for the territory of the Federation BiH; the Ministry of Finance of
    Republika Srpska for the territory of Republika Srpska, and the Br??ko District Finance Directorate for the
    territory of the Br??ko District;
    For taxes referred to in Article 2, paragraph 1, subparagraph b.iii.C, the competent authority shall be the
    Indirect Taxation Authority.

  • BOTSWANA
    Sitoutumispäivä: 29.09.2020 A
    Voimaantulopäivä: -
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the
    Secretary General of the OECD on 15 June 2021

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Botswana will not provide any
    form of assistance in relation to the taxes of other Parties included in the following categories of Article 2,
    paragraph 1:
    Article 2, paragraph 1.b.i;
    Article 2, paragraph 1.b.ii;
    Article 2, paragraph 1.b.iii.E;
    Article 2, paragraph 1.b.iii.F;
    Article 2, paragraph 1.b.iii.G, and
    Article 2, paragraph 1.b.iv.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Botswana will not provide
    assistance with regard to the service of documents as described in Article 17 of the Convention, for all
    taxes. This reservation does not apply to the service of documents as described in Article 17,
    paragraph 3, of the Convention.
    The Republic of Botswana ratifies the Convention on Mutual Administrative Assistance in Tax Matters as
    amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters,
    with the following notifications:
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    - Income tax;
    - Withholding tax on royalties;
    - Withholding tax on dividend tax;
    - Withholding tax on interest;
    - Withholding tax on technical fees;
    - Withholding tax on tax on foreign entertainers and sportspersons.
    Article 2, paragraph 1.a.ii: Capital gains tax.
    Article 2, paragraph 1.b.iii.A: Capital transfer tax.
    Article 2, paragraph 1.b.iii.B: Transfer duty.
    Article 2, paragraph 1.b.iii.C: Value added tax.
    Article 2, paragraph 1.b.iii.D: Excise duty.

  • BRASILIA
    Sitoutumispäivä: 01.06.2016 R
    Voimaantulopäivä: 01.10.2016
    Varauma:

    Reservations and declarations:

    Pursuant to Article 30, paragraph 1 (b), of the Convention, the Government of Brazil will not provide assistance in the recovery of any tax claim, or in the recovery of administrative fines, for all taxes.
    Pursuant to Article 30, paragraph 1 (d), of the Convention, the Government of Brazil will not provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1 (e), of the Convention, the Government of Brazil will not permit the servide of documents through the post, as provided for in paragraph 3 of Article 17 of the Convention.

    Annex A
    Article 2, paragraph 1:
    a) paragraph 1.a.i: Income Tax and Social Contribution on Net Profits;
    b) paragraph 1.b.ii: Contribution for the Program for Social Integration and Social Contribution for the Financing of Social Security;
    c) paragraph 1.b.iii.D: Ta on Industrialized Products;
    d) paragraph 1.b.iii.G: any other taxes administered by the Secretariat of the Federal Revenue of Brazil.

    Annex B
    The Competent Authority for the Federative Republic of Brazil is the Secretary of the Federal Revenue of Brazil.

  • BRUNEI
    Sitoutumispäivä: 28.03.2019 R
    Voimaantulopäivä: -
    Varauma:

    Reservation and declarations:

    Pursuant to Article 30, paragraph 1.a, of the Convention, Brunei Darussalam reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the categories listed in Article 2, paragraph 1.b.
    Pursuant to Article 30, paragraph 1.b, of the Convention, Brunei Darussalam reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1.c, of the Convention, Brunei Darussalam reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Brunei Darussalam or, where a reservation has previously been made under sub-paragraph a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.
    Pursuant to Article 30, paragraph 1.d, of the Convention, Brunei Darussalam reserves the right not to provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.e, of the Convention, Brunei Darussalam reserves the right not to permit the service of documents through the post as provided for in Article 17, paragraph 3.
    Pursuant to Article 30, paragraph 1.f, of the Convention, Brunei Darussalam reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Brunei Darussalam, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Brunei Darussalam.

    Annex A - Taxes to which the Convention would apply
    For the purposes of Article 2, paragraph 2, of the Convention, the following taxes apply in the case of Brunei Darussalam:
    Article 2, paragraph 1.a.i:
    ??? Income tax imposed under Income Tax Act (Chapter 35), and
    ??? Petroleum profits tax imposed under Income Tax (Petroleum) Act (Chapter 119).

    Annex B - Competent authorities
    For the purposes of Article 3, paragraph 1.d, of the Convention, the term ???competent authority??? in relation to Brunei Darussalam means the Minister of Finance and Economy or his authorised representative.

    Annex C - Definition of the word "national" for the purpose of the Convention
    For the purposes of Article 3, paragraph 1.e, of the Convention, the term ???national??? in relation to Brunei Darussalam means any individual possessing the nationality of Brunei Darussalam, and any legal person, partnership or association deriving its status as such from the laws in force in the Brunei Darussalam.
    In accordance with Article 4, paragraph 3, of the Convention, Brunei Darussalam declares that its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7 of the Convention.
    In accordance with Article 9, paragraph 3, of the Convention, Brunei Darussalam declares that it will not accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the Convention.

    *******************

    BRUNEI DARUSSALAM

    Declaration transmitted by the Embassy of Brunei Darussalam to France and registered at the Secretariat General of the OECD on 2 January 2020 - Or. Engl.
    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.
    Considering that Brunei Darussalam has committed to automatically exchange information in / as of 2018 and that, in order to be able to automatically exchange information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters (hereafter the ???amended Convention???) in accordance with the timeline to which it has committed, Brunei Darussalam has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the ???CRS MCAA???) on 12 December 2019;
    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for administrative assistance related to taxable periods beginning on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party;
    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may mutually agree that the amended Convention shall have effect for administrative assistance related to earlier taxable periods or charges to tax;
    Mindful that information may only be sent by a jurisdiction under the amended Convention with respect to taxable periods or charges to tax of the receiving jurisdiction for which the amended Convention is in effect and that, as a consequence, sending jurisdictions for which the Convention has newly entered into force in a given year are only in a position to provide administrative assistance to receiving jurisdictions for taxable periods beginning or charges to tax arising on or after 1 January of the following year;
    Acknowledging that an existing Party to the amended Convention would be able to receive information under Article 6 of the amended Convention and the CRS MCAA from a new Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties declare to agree that another date of effect is applicable;
    Further acknowledging that, therefore, a new Party to the amended Convention would be able to send information under Article 6 of the amended Convention and the CRS MCAA to an existing Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if both Parties declare to agree that another date of effect is applicable;
    Recognising that the information received under Article 6 of the amended Convention and the CRS MCAA may lead to follow-up requests by the receiving jurisdiction to the sending jurisdiction, which would relate to the same reporting period for which the sending jurisdiction has automatically exchanged information under the CRS MCAA;
    Confirming that the capacity of a jurisdiction to send CRS-related information under Article 6 of the amended Convention and the CRS MCAA, as well as information relating to follow-up requests pursuant to Article 5 of the amended Convention, shall be governed by the terms of the CRS MCAA, including the relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods or charges to tax of the receiving jurisdiction to which such information relates;
    The Government of Brunei Darussalam declares that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between Brunei Darussalam and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction.
    The Government of Brunei Darussalam declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between Brunei Darussalam and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, when such assistance concerns follow-up requests related to information exchanged under the CRS MCAA with respect to reporting periods of the sending jurisdiction covered by the CRS MCAA.

  • BULGARIA
    Sitoutumispäivä: 14.03.2016 R
    Voimaantulopäivä: 01.07.2016
    Varauma:

    Declarations contained in a Note Verbale from the Permanent Representation of Bulgaria and in the instrument of ratification, deposited simultaneously on 14 March 2016 - Or. Engl.
    ANNEX A ??? Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    ??? Personal income tax
    ??? Corporate income tax
    Article 2, paragraph 1.a.ii:
    ??? --
    Article 2, paragraph 1.a.iii:
    ??? --
    Article 2, paragraph 1.b.i:
    ??? --
    Article 2, paragraph 1.b.ii:
    ??? Compulsory social security contributions payable to general government or to social security institutions established under public law.
    Article 2, paragraph 1.b.iii.A:
    ??? --
    Article 2, paragraph 1.b.iii.B:
    ??? --
    Article 2, paragraph 1.b.iii.C:
    ??? Value added tax
    Article 2, paragraph 1.b.iii.D:
    ??? --
    Article 2, paragraph 1.b.iii.E:
    ??? --
    Article 2, paragraph 1.b.iii.F:
    ??? --
    Article 2, paragraph 1.b.iii.G:
    ??? --
    ANNEX B ??? Competent authorities
    The Minister of Finance, the Executive Director of the National Revenue Agency or their authorised representative will be the competent authorities in Bulgaria under Annex B of the Convention.

  • BURKINA FASO
    Sitoutumispäivä: 25.08.2016 A
    Voimaantulopäivä: -
  • CHILE
    Sitoutumispäivä: 07.07.2016 R
    Voimaantulopäivä: -
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016

    According to Article 30, paragraph 1.a, of the Convention, the Republic of Chile reserves the right not to provide any form assistance in relation to the taxes of other Parties, save for the ones included by Chile in Annex A to the Convention.
    According to Article 30, paragraph 1.b, of the Convention, the Republic of Chile reserves the right not to provide any assistance in the recovery of any tax claim or in the recovery of an administrative fine, for all taxes.
    According to Article 30, paragraph 1.d, of the Convention, the Republic of Chile reserves the right not to provide assistance in the service of documents.
    According to Article 30, paragraph 1.e, of the Convention, the Republic of Chile reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17 of the Convention.
    According to Article 30, paragraph 1.f, of the Convention, the Republic of Chile reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention entered into force in respect of Chile, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention entered into force in respect of Chile.
    According to Article 4, paragraph 3, of the Convention, the Republic of Chile declares that its authorities may inform its resident before transmitting information concerning them, in conformity with Article 5 and Article 7 of the Convention.
    According to Article 9, paragraph 3, of the Convention, the Republic of Chile will not accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the Convention.

    ANNEX A - Taxes to which the Convention would apply.
    i. Tax included in the income tax
    ii. Sales and Services Tax Act
    iii. Estate, inheritance or gift taxes
    ANNEX B - Competent authorities
    The Minister of Finance, the Commissioner of the Chilean Internal Revenue Service, or their authorised representatives.
    ANNEX C - Definition of the term "national" for the purpose of the Convention
    The Republic of Chile, according to Article 3, paragraph 1.e, of the Convention, declares that the term "national" means any individual possessing the Chilean nationality; and any legal person or association organised under the laws in force in the Republic of Chile.

  • COOKINSAARET
    Sitoutumispäivä: 29.05.2017 R
    Voimaantulopäivä: 01.09.2017
    Varauma:

    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

    Considering that the Cook Islands have committed to automatically exchange information in/as of 2018 and that, in order to be able to automatically exchange information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters (hereafter the ???amended Convention???) in accordance with the timeline to which it has committed, the Cook Islands have signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the ???CRS MCAA???) on 28 October 2016;

    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for administrative assistance related to taxable periods beginning on or after 1 January of the year following
    the one in which the amended Convention entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party;

    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may mutually agree that the amended Convention shall have effect for administrative assistance related to earlier taxable periods or charges to tax; Mindful that information may only be sent by a jurisdiction under the amended Convention with respect to taxable periods or charges to tax of the receiving jurisdiction for which the amended Convention is in effect and that, as a consequence, sending jurisdictions for which the Convention has newly entered into
    force in a given year are only in a position to provide administrative assistance to receiving jurisdictions for taxable periods beginning or charges to tax arising on or after 1 January of the following year;

    Acknowledging that an existing Party to the amended Convention would be able to receive information under Article 6 of the amended Convention and the CRS MCAA from a new Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties declare to agree that another date of effect is applicable; Further acknowledging that, therefore, a new Party to the amended Convention would be able to send information under Article 6 of the amended Convention and the CRS MCAA to an existing Party with
    respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if both Parties declare to agree that another date of effect is applicable;

    Recognising that the information received under Article 6 of the amended Convention and the CRS MCAA may lead to follow-up requests by the receiving jurisdiction to the sending jurisdiction, which would relate to the same reporting period for which the sending jurisdiction has automatically exchanged information under the CRS MCAA; Confirming that the capacity of a jurisdiction to send CRS-related information under Article 6 of the amended Convention and the CRS MCAA, as well as information relating to follow-up requests pursuant to Article 5 of the amended Convention, shall be governed by the terms of the CRS MCAA, including the relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods
    or charges to tax of the receiving jurisdiction to which such information relates;

    The Cook Islands declare that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between the Cook Islands and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction.

    The Cook Islands declare that the amended Convention shall also have effect for administrative assistance under its Article 5, between the Cook Islands and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, when such assistance concerns follow-up requests related to information exchanged under the CRS MCAA with respect to reporting periods of the sending jurisdiction covered by the CRS MCAA.

  • COSTA RICA
    Sitoutumispäivä: 05.04.2013 R
    Voimaantulopäivä: 01.08.2013
    Varauma:

    Article 2

    ANNEX A ??? Existing taxes to which the Convention shall apply:

    Article 2, paragraph 1.a.i:
    Income Tax (Impuesto sobre la renta).

    Article 2, paragraph 1.b.ii:
    Contributions made to the Costa Rican Social Security (Contribuciones a la caja Costarricense del Seguro Social).

    Article 2, paragraph 1.b.iii. B:
    Real estate tax (Impuesto a la propriedad de bienes inmuebles).

    Article 2, paragraph 1.b.iii. C:
    Value Added Tax (Impuesto general sobre las ventas).

    Article 2, paragraph 1.b.iii. E:
    Vehicles, ships and aircrafts tax (Impuesto a la propriedad de veh??culos, embarcaciones y aeronaves).

    Article 30

    Pursuant to Article 30, paragraph 1.a, of the Convention, Costa Rica reserves the right not to provide any form of assistance in relation to taxes of other Parties included in one of the following categories listed in Article 2, paragraph 1.b:

    i: taxes on income, profits, capital gains or net wealth which are imposed on behalf of political divisions or local authorities of a Party;
    iii: A. estate, inheritance or gift tax;
    iii: D. specific taxes on goods and services such as excise taxes;
    iii: F. taxes on the use or ownership of movable property other than motor vehicles;
    iii: G. any other taxes.

    Article 30

    Pursuant to Article 30, paragraph 1.b, of the Convention, Costa Rica reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

    Article 30

    Pursuant to Article 30, paragraph 1.c, of the Convention, Costa Rica reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made under sub-paragraph a or b above, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

    Article 30

    Pursuant to Article 30, paragraph 1.d, of the Convention, Costa Rica reserves the right not to provide assistance in the service of documents for all taxes.

    Article 30

    Pursuant to Article 30, paragraph 1.e, of the Convention, Costa Rica reserves the right not to permit the service of documents though the post as provided for in paragraph 3 of Article 17.

    Article 30

    Pursuant to Article 30, paragraph 1.f, of the Convention, Costa Rica reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

    Article 3

    ANNEX B ??? Competent authorities

    The Director of the Tax Administration (Director General de Tributaci??n).

  • DOMINIKAANINEN TASAVALTA
    Sitoutumispäivä: 02.08.2019 R
    Voimaantulopäivä: 01.12.2019
    Varauma:

    Reservations and Declarations contained in the instrument of ratification deposited with the Secretariat General of the OECD on 2 August 2019, completed by a Note verbale from the Embassy of the Dominican Republic in France, dated 4 September 2019, registered at the Secretariat General of the OECD on 6 September 2019

    In accordance with Article 30, paragraph 1.a, of the Convention, the Dominican Republic reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in one of the following categories listed in Article 2, paragraph 1.b:
    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;
    ii. compulsory social security contributions payable to the general government or social security institutions established under public law;
    iii. taxes on the use or ownership of motor vehicles;
    iv. taxes on the use or ownership of movable property other than motor vehicles;
    v. any other taxes;
    vi. taxes in categories other than those referred to in number i and ii, which are imposed on behalf of political subdivisions or local authorities of a Party.
    In accordance with Article 30, paragraph 1.b, of the Convention, the Dominican Republic reserves the right not to provide assistance in the collection of any tax claim, or in the recovery of an administrative fine, for all taxes.
    In accordance with Article 30, paragraph 1.c, of the Convention, the Dominican Republic reserves the right not to provide assistance in respect of any tax claim which is in existence at the date of entry into force of the Convention with respect to that State or, where a reservation has previously been made under sub-paragraphs a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.
    In accordance with Article 30, paragraph 1.d, of the Convention, the Dominican Republic reserves the right not to provide assistance in the service of documents, for all taxes.
    In accordance with Article 30, paragraph 1.e, of the Convention, the Dominican Republic reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.
    3 / 5
    In accordance with Article 30, paragraph 1.f, of the Convention, the Dominican Republic reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Dominican Republic, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Dominican Republic.
    Annex A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i: Taxes on profits, capital or equity gains of natural or legal persons.
    Article 2, paragraph 1.b.iii.A: Taxes on property, inheritance or donations.
    Article 2, paragraph 1.b.iii.B: Taxes on real estate.
    Article 2, paragraph 1.b.iii.C: General consumption taxes.
    Article 2, paragraph 1.b.iii.D: Specific taxes on goods and services.
    Annex B - Competent authorities
    The Minister of Finance or his authorised representative.
    Annex C ??? Definition of the term ???nationals???
    In relation to the Dominican Republic, the term ???national??? means any citizen and any legal entity or any other collective entity, whose existence derives from the current laws in each of the Parties.
    Regarding the definition of ???national???, the Dominican Republic points out that it recognizes citizens with dual nationalities, meaning the Dominican citizen who, by any legal means, acquires a secondary nationality and still maintains the Dominican nationality for our legal purposes. This definition is intended to include Dominican nationals in every country in which their Dominican nationality is legally recognized. If the other Party does not recognize dual nationality, the term should only apply to the extent of the Dominican Republic.
    Pursuant to Article 9, paragraph 3, of the Convention, the Dominican Republic declares its intention not to accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the Convention.
    In accordance with Article 29, paragraph 1, of the Convention, the Dominican Republic declares that, with respect to it, the Convention will apply to the entire territory of the Dominican Republic, using the geographical sense, which includes the eastern part of the island of Santo Domingo, its adjacent islands and the set of natural elements of its marine geomorphology. Its irreducible land limits are set by the 1929 Border Treaty and its 1936 Revision Protocol. In addition, it includes the corresponding territorial sea, sea floor and subsoil, as well as the continuous zone, exclusive economic zone and the continental shelf; it also contains the airspace over the national territory, the electromagnetic spectrum and the space where it acts, in accordance with its legislation and international law.

  • ECUADOR
    Sitoutumispäivä: 26.08.2019 R
    Voimaantulopäivä: 01.12.2019
    Varauma:

    Reservations and Declarations contained in a Note Verbale from the Embassy of Ecuador in France and in the instrument of ratification, deposited with the Secretariat General of the OECD on 26 August 2019

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Ecuador reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b, of the Convention:
    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;
    ii. compulsory social security contributions payable to the general government or social security institutions established under public law;
    vi. taxes in categories referred to in sub-paragraph iii which are imposed on behalf of political subdivisions or local authorities of a Party.
    In accordance with Article 30, paragraph 1.e, of the Convention, the Republic of Ecuador reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.
    Annex A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    ??? Income tax (impuesto a la renta)
    ??? Participation of labour in profits of mining rights holders, attributable to the State (participaci??n laboral en las utilidades de titulares de derechos mineros, atribuibles al Estado)
    ??? Mineral exploitation royalties (Regal??as a la explotaci??n de minerales)
    ??? Adjustment required to comply with Article 408 of the Constitution, applicable to the exploitation of non-renewable natural resources (Ajuste necesario para cumplir con lo dispuesto en el art??culo 408 de la Constituci??n, correspondiente a la explotaci??n de recursos naturales no renovables)
    Article 2, paragraph 1.a.ii:
    ??? Income tax on gains from the alienation of shares, participations, other rights in the capital of entities, or other exploration, exploitation, concession or similar rights (Impuesto a la renta ??nico a la utilidad en la enajenaci??n de acciones, participaciones, otros derechos representativos de capital u otros derechos que permitan la exploraci??n, explotaci??n, concesi??n o similares)

    Article 2, paragraph 1.a.iii:
    ??? Tax on assets held abroad (Impuesto a los activos en el exterior)
    Article 2, paragraph 1.b.iii.A:
    ??? Income tax on worth increases from inheritances, estates, gifts, findings and similar sources (Impuesto a la renta por incrementos patrimoniales provenientes de herencias, legados, donaciones, hallazgos y otros de naturaleza an??loga)
    Article 2, paragraph 1.b.iii.C:
    ??? Value added tax (Impuesto al valor agregado IVA).
    Article 2, paragraph 1.b.iii.D:
    ??? Special consumption tax (impusto a los consumos especiales ICE)
    Article 2, paragraph 1.b.iii.E:
    ??? Tax on the ownership of motor vehicles (Impuesto a la propriedad de veh??culos motorizados)
    Article 2, paragraph 1.b.iii.G:
    ??? Ecuadorian simplified tax regime (Regimen impositivo simplificado ecuatoriano RISE)
    ??? Currency outflow tax (Impuesto a la salida de divisas ISD)
    ??? Redeemable tax on nonreturnable plastic bottles (Impuesto redimible a las botellas pl??sticas no retornables)
    ??? Mining concession conservation patents (Patentes de conservaci??n de concesiones mineras)
    Annex B - Competent authorities
    The Director of the Internal Revenue Service or its authorised representative.
    Annex C ??? Definition of the term ???nationals???
    In relation to the Republic of Ecuador, the term ???national??? means any individual possessing Ecuadorian nationality or citizenship and any legal person, association or other entity deriving its status as such from the laws in force in Ecuador.

    **********************
    Declaration transmitted by the Embassy of Ecuador to France and registered at the Secretariat
    General of the OECD on 1
    st September 2021

    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority
    Agreement on Automatic Exchange of Financial Account Information.
    Considering that Ecuador has committed to automatically exchange information in 2021 of information of
    2020 and that, in order to be able to automatically exchange information under Article 6 of the Convention
    on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention
    on Mutual Administrative Assistance in Tax Matters (hereafter the ???amended Convention???) in accordance
    with the timeline to which it has committed, Ecuador has signed a Declaration on joining the Multilateral
    Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the
    ???CRS MCAA???) on 29 October 2018;
    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for administrative
    assistance related to taxable periods beginning on or after 1 January of the year following the one in which
    the amended Convention entered into force in respect of a Party, or where there is no taxable period, for
    administrative assistance related to charges to tax arising on or after 1 January of the year following the
    one in which the amended Convention entered into force in respect of a Party;
    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may
    mutually agree that the amended Convention shall have effect for administrative assistance related to
    earlier taxable periods or charges to tax;
    Mindful that information may only be sent by a jurisdiction under the amended Convention with respect to
    taxable periods or charges to tax of the receiving jurisdiction for which the amended Convention is in effect
    and that, as a consequence, sending jurisdictions for which the Convention has newly entered into force
    in a given year are only in a position to provide administrative assistance to receiving jurisdictions for
    taxable periods beginning or charges to tax arising on or after 1 January of the following year;
    Acknowledging that an existing Party to the amended Convention would be able to receive information
    under Article 6 of the amended Convention and the CRS MCAA from a new Party with respect to earlier
    taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties declare
    to agree that another date of effect is applicable;

    Further acknowledging that, therefore, a new Party to the amended Convention would be able to send
    information under Article 6 of the amended Convention and the CRS MCAA to an existing Party with
    respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if
    both Parties declare to agree that another date of effect is applicable;
    Recognising that the information received under Article 6 of the amended Convention and the CRS MCAA
    may lead to follow-up requests by the receiving jurisdiction to the sending jurisdiction, which would relate
    to the same reporting period for which the sending jurisdiction has automatically exchanged information
    under the CRS MCAA;
    Confirming that the capacity of a jurisdiction to send CRS-related information under Article 6 of the
    amended Convention and the CRS MCAA, as well as information relating to follow-up requests pursuant
    to Article 5 of the amended Convention, shall be governed by the terms of the CRS MCAA, including the
    relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods
    or charges to tax of the receiving jurisdiction to which such information relates;
    Ecuador declares that the amended Convention shall have effect in accordance with the terms of the CRS
    MCAA for administrative assistance under the CRS MCAA between Ecuador and the other Parties to the
    amended Convention that have made similar declarations, irrespective of the taxable periods or charges
    to tax to which such information relates in the receiving jurisdiction.
    Ecuador declares that the amended Convention shall also have effect for administrative assistance under
    its Article 5, between Ecuador and the other Parties to the amended Convention that have made similar
    declarations, irrespective of the taxable periods or charges to tax to which such information relates in the
    receiving jurisdiction, when such assistance concerns follow-up requests related to information exchanged
    under the CRS MCAA with respect to reporting periods of the sending jurisdiction covered by the CRS
    MCAA.

  • EL SALVADOR
    Sitoutumispäivä: 26.02.2019 R
    Voimaantulopäivä: 01.06.2019
    Varauma:

    Pursuant to Article 30, paragraph 1.a, of the Convention, El Salvador reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b:

    i.: Taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

    iii.A.: Estate, inheritance or gift taxes,
    iii.F.: Taxes on the use or ownership of movable property other than motor vehicles,
    iii.G.: Any other taxes;

    iv.: Taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.
    Period covered: 01/06/2019 -
    Articles concerned : 30

    Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 26 February 2019 - Or. Engl., and supplemented by a Note verbale from the Embassy of El Salvador in France, dated 20 May 2019, registered at the Secretariat General of the OECD on 21 May 2019 ??? Or. Fr.

    Pursuant to Article 30, paragraph 1.b, of the Convention, El Salvador reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    Period covered: 01/06/2019 -
    Articles concerned : 30

    Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 26 February 2019 - Or. Engl., and supplemented by a Note verbale from the Embassy of El Salvador in France, dated 20 May 2019, registered at the Secretariat General of the OECD on 21 May 2019 ??? Or. Fr.

    Pursuant to Article 30, paragraph 1.f, of the Convention, El Salvador reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.
    Period covered: 01/06/2019 -
    Articles concerned : 28, 30

  • ESPANJA
    Sitoutumispäivä: 10.08.2010 R
    Voimaantulopäivä: 01.12.2010
    Varauma:

    Article 2

    Annex A. Taxes to which the Convention applies

    Article 2, paragraph 1.a.i.:
    Taxes on income or profits, or taxes on capital gains which are imposed separately from the tax on income or profits, and taxes on net wealth, imposed on behalf of the member States :

    - Personal Income Tax;
    - Non-Residents Income Tax;
    - Corporate tax;
    - Wealth Tax.

    Article 2, paragraph 1.b.i.:
    Any of the above which are imposed on behalf of political subdivisions or local authorities of a Signatory State :

    - Tax on the Increase in the Value of Urban Land;
    - Tax on Economic Activities.

    Article 2, paragraph 1.b.ii.:
    Payments and other Social Security resources paid to the Government or to the Social Security Institutions established by law.

    Article 2, paragraph 1.b.iii.:
    Taxes in other categories, except customs duties, imposed on behalf of a signatory State, namely :

    A. Inheritance and Gift Tax.

    B. Tax on Immovable Property.

    C. Value-Added Taxes;
    General Indirect Tax for the Canary Islands;
    Tax on Imports and Deliveries of Goods in the Canary Islands;
    Tax on Production, Services and Imports in the cities of Ceuta and Melilla.

    D. Tax on the Retail Sales of Certain Hydrocarbons;
    Insurance Premium Tax;
    Beer Tax;
    Tax on Wine and Fermented Beverages;
    Tax on Intermediate Products;
    Tax on Alcohol and Derived Beverages;
    Hydrocarbon Tax;
    Tobacco Products Tax,
    Electricity Tax;
    Special Tax on Certain Means of Transport.

    E. Tax on Motor Vehicles.

    F.Tax on Capital Transfers and Documented Legal Acts.

    Article 2, paragraph 1.b.iv.:
    Any of the above which are imposed on behalf of political subdivisions or local authorities:

    - Special Tax of the Autonomous Community of the Canary Islands on Petroleum-based Fuels;
    - Tax on Construction, Installations and Works.

    Article 3

    Annex C. Definition of the word "national" for the purpose of the Convention

    1. All individuals of Spanish nationality.

    2. All legal persons, partnerships or associations and other institutions set up in accordance with current Spanish legislation.

    Annex B. Competent Authorities

    The Minister of Economy and Finance, or the authorised representative thereof, and within the sphere of their powers, the Minister of Employment and Immigration or the Minister that, in the future, may replace him, regardless of the fact that, in practice, such functions may be carried out by the General Treasury of the Social Security.

    Article 29

    In the event that this Convention on Mutual Administrative Assistance in Tax Matters were to be applied to Gibraltar, Spain wishes to make the following declaration :

    1. Gibraltar is a non-autonomous territory for the international relations of which the United Kingdom is responsible and which is subject to a decolonisation process in accordance with the relevant decisions and resolutions of the General Assembly of the United Nations.

    2. The authorities of Gibraltar are of a local nature and exercise exclusively internal competences which have their origin and their foundation in the distribution and attribution of competences performed by the United Kingdom, in compliance with its internal legislation, in its capacity as sovereign State on which the mentioned non-autonomous territory depends.

    3. As a result, should the Gibraltarian authorities participate in the application of this Convention it will be understood as effected exclusively within the scope of the internal competences of Gibraltar, and it cannot be considered to produce any change whatsoever in relation with what was established in the two preceding paragraphs.

    Spain informs the Organisation for Economic Co-Operation and Development in Paris that the procedure set out in the Agreed Arrangements relating to Gibraltar Authorities in the Context of Mixed Agreements, agreed between Spain and the United Kingdom on 19 December 2007 (together with the Arranged Agreements relating to Gibraltar Authorities in the Context of EU and EC Instruments and Related Treaties, of 19 April 2000) (*), is applicable to the present Convention.

    [(*) Note by the Secretariat: The additional information appended to this communication from Spain are available, in English only, upon request to the Treaty Office.]

  • ESWATINI
    Sitoutumispäivä: 29.09.2020 A
    Voimaantulopäivä: -
  • ETELÄ-AFRIKKA
    Sitoutumispäivä: 21.11.2013 R
    Voimaantulopäivä: 01.03.2014
    Varauma:

    Annex A ??? Taxes to which the Convention would apply

    Article 2, paragraph 1.a.i:
    Income tax;
    Withholding tax on royalties;
    Tax on foreign entertainers and sportspersons;
    Turnover tax on micro businesses;
    Dividend tax;
    Withholding tax on interest, effective date 1 March 2015.

    Article 2, paragraph 1.a.ii:
    Capital gains.

    Article 2, paragraph 1.b.iii.A:
    Estate duty;
    Donations tax.

    Article 2, paragraph 1.b.iii.B:
    Transfer duty.

    Article 2, paragraph 1.b.iii.C:
    Value Added Tax.

    Article 2, paragraph 1.b.iii.D:
    Excise tax.

    Article 2, paragraph 1.b.iii.G:
    Securities transfer taxes.

    ANNEX C - Definition of a "national" for the purpose of the Convention

    Any individual possessing the nationality or citizenship of South Africa and any legal person, partnership, association, or other entity deriving its status as such from the laws in force in South Africa.

  • ETELÄ-KOREA
    Sitoutumispäivä: 26.03.2012 R
    Voimaantulopäivä: 01.07.2012
    Varauma:

    Article 2

    Annex A. Taxes to which the Convention would apply

    I. Article 2, paragraph 1.a.i.:

    - income tax;
    - corporation tax;
    - special tax for rural development.

    II. Article 2, paragraph 1.b.iii.:

    1. Category A:
    - inheritance tax;
    - gift tax.

    2. Category B:
    - comprehensive real estate holding tax.

    3. Category C:
    - value added tax.

    4. Category D:
    - individual consumption tax;
    - liquor tax.

    Article 3

    Annex C. Definition of the word "national" for the purpose of the Convention

    1. Any individual possessing the nationality of the Republic of Korea.
    2. Any legal person, partnership or association deriving its status as such from the laws in force in the Republic of Korea.

    Annex B. Competent Authorities

    The Minister of Strategy and Finance or his authorised representative.

    Article 30

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Korea will not provide any form of assistance in relation to the taxes of the other parties described in Article 2, paragraph 1, b, i or ii or iii E, F, G or iv of the Convention.

    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Korea will not provide assistance in the service of documents with regard to judicial decisions for all taxes.

    Pursuant to Article 30, paragraph 1.e, of the Convention, the Republic of Korea will not permit the service of documents with regard to judicial decisions through the post.

  • GEORGIA
    Sitoutumispäivä: 28.02.2011 R
    Voimaantulopäivä: 01.06.2011
    Varauma:

    Article 2

    ANNEX A ? Taxes to which the Convention would apply:

    Article 2, paragraph 1.a:
    i. income tax;
    profit tax;

    ii. -

    iii. -

    Article 2, paragraph 1.b:
    i. -

    ii. -

    iii. A. ? -
    B. ? property tax;
    C. ? value-added tax;
    D. ? excise tax;
    E. ? -
    F. ? -
    G. ? -

    iv. -

    Article 3

    ANNEX B ? Competent authorities

    The Ministry of Finance or its authorised representative.

    ANNEX C ? Definition of the word "national" for the purpose of the Convention

    - any individual possessing the citizenship of Georgia;
    - any legal person or partnership or association deriving its status as such from the laws in force in Georgia.

  • GHANA
    Sitoutumispäivä: 29.05.2013 R
    Voimaantulopäivä: 01.09.2013
    Varauma:

    Article 2

    Annex A ??? Taxes to which the Convention would apply:

    Article 2, paragraph 1.a.i:
    Income tax
    Petroleum income tax
    Mineral royalties
    Withholding tax on interest
    Withholding tax on dividend
    Withholding tax on goods and services

    Article 2, paragraph 1.a.ii:
    Capital gains tax

    Article 2, paragraph 1.b.iii. A:
    Gift tax

    Article 2, paragraph 1.b.iii. C:
    Value added tax

    Article 2, paragraph 1.b.iii. D:
    Excise tax

    Article 3

    ANNEX B ??? Competent Authorities

    The Commissioner-General of the Ghana Revenue Authority or an authorized representative.
    Address:
    Commissioner-General
    Ghana Revenue Authority
    GP 2202 Accra, Ghana

  • GUATEMALA
    Sitoutumispäivä: 09.06.2017 R
    Voimaantulopäivä: 01.10.2017
    Varauma:

    In accordance with Article 30, paragraph 1.a, of the Convention, the Republic of Guatemala reserves the right not to grant any form of assistance in relation to the taxes of other Parties in any of the categories included in Article 2, paragraph 1.b:

    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

    ii. compulsory social security contributions payable to general government or to social security institutions established under public law, and

    iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

    A. taxes on estate, inheritance or gift,
    B. taxes on immovable property,
    C. general consumption taxes, such as value-added or sales taxes,
    D. specific taxes on goods and services such as excise taxes,
    E. taxes on the use or ownership of motor vehicles,
    F. taxes on the use or ownership of movable property other than motor vehicles,
    G. any other taxes.

    iv. taxes in categories referred to in sub-paragraph iii which are imposed on behalf of political subdivisions or local authorities of a Party.

    In accordance with Article 30, paragraph 1.b, of the Convention, the Republic of Guatemala reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an
    administrative fine for all taxes.

    In accordance with Article 30, paragraph 1.c, of the Convention, the Republic of Guatemala reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Guatemala or, where a reservation has previously been made under sub-paragraph a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

    In accordance with Article 30, paragraph 1.d, of the Convention, the Republic of Guatemala reserves the right not to provide assistance in the service of documents for all taxes.
    In accordance with Article 30, paragraph 1.e, of the Convention, the Republic of Guatemala reserves the right not to permit the service of documents through the post as provided for in Article 17,
    paragraph 3.

    In accordance with Article 30, paragraph 1.f, of the Convention, the Republic of Guatemala reserves the right to apply Article 28, paragraph 7, exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Guatemala, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Guatemala.

    ANNEX A - Taxes to which the Convention would apply

    Article 2, paragraph 1.a.i.: Taxes on income of profits.

    Income Tax, applied to:
    - Income from profit activities (Rentas de las actividades lucrativas)
    - Work income (Rentas del trabajo)
    - Income from capital and capital gains (Rentas del capital y las ganancias de capital)

    Article 2, paragraph 1.a.ii.: Taxes on capital gains which are imposed separately from the tax on income or profits.
    Income tax includes all capital gains (El impuesto Sobre la Renta incluye todas la ganancias de capital).

    ANNEX B - Competent authorities

    The Superintendency of Tax Administration.

  • INTIA
    Sitoutumispäivä: 21.02.2012 R
    Voimaantulopäivä: 01.06.2012
    Varauma:

    Article 2

    ANNEX A ??? Taxes to which the Convention would apply

    For India, the Convention shall apply to taxes of every kind and description which fall within the categories set out in Article 2.1a and 2.1.b, whether such taxes are imposed by the Central Government or the Governments of political sub-divisions or local authorities and irrespective of the manner in which they are levied.

    Article 3

    ANNEX B ??? Competent Authorities

    For India, the term ???competent authority??? means the Minister of Finance or his authorised representatives i.e., the Joint Secretary, Foreign Tax and Tax Research Division-I and the Joint Secretary, Foreign Tax and Tax Research Division-II, Department of Revenue, Ministry of Finance.

  • IRLANTI
    Sitoutumispäivä: 29.05.2013 R
    Voimaantulopäivä: 01.09.2013
    Varauma:

    Article 30

    Pursuant to Article 30, paragraph 1.a., of the Convention, Ireland will not provide any form of assistance in relation to the taxes of other Parties described in Article 2, paragraph 1.b i, ii or iv, of the Convention (taxes imposed by or on behalf of political subdivisions or local authorities and social security contributions).

    Pursuant to Article 30, paragraph 1.b., of the Convention, Ireland will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

    Pursuant to Article 30, paragraph 1.d., of the Convention, Ireland will not provide assistance in the service of documents for all taxes.

    Article 2

    ANNEX A ??? Existing taxes to which the Convention shall apply:

    For the purposes of Article 2, paragraph 2, of the Convention, the following taxes shall apply in the case of Ireland:

    Article 2, paragraph 1.a.i:
    - income tax (including the universal social charge)
    - corporation tax

    Article 2, paragraph 1.a.ii:
    - capital gains tax

    Article 2, paragraph 1.b.iii.A:
    - capital acquisitions tax

    Article 2, paragraph 1.b.iii.B:
    - local property tax

    Article 2, paragraph 1.b.iii.C:
    - value added tax

    Article 2, paragraph 1.b.iii.D:
    - excise duties

    Article 2, paragraph 1.b.iii.G:
    - stamp duties

    Article 3

    ANNEX B ??? Competent Authorities

    For the purposes of Article 3, paragraph 1.d., of the Convention, the term ???competent authority??? means the Revenue Commissioners or their authorised representative.

    Article 3

    ANNEX C ??? Definition of the word "national" for the purpose of the Convention

    For the purposes of Article 3, paragraph 1.e., of the Convention, the term ???nationals??? in relation to Ireland shall be understood as any individuals possessing the citizenship of Ireland, and any legal person, partnership, association or other entity deriving its status as such from the laws in force in Ireland.

    Article 29
    For the purposes of Article 29 of the Convention, the territory to which the Convention shall apply shall be Ireland, including any area outside the territorial waters of Ireland which has been or may hereafter be designated under the laws of Ireland concerning the Exclusive Economic Zone and the Continental Shelf, as an area within which Ireland may exercise such sovereign rights and jurisdiction as are in conformity with international law.

  • ISLANTI
    Sitoutumispäivä: 22.07.1996 R
    Voimaantulopäivä: 01.11.1996
    Varauma:

    The Government of Iceland declares, pursuant to Article 29, paragraph 1, of the Convention, that with respect to Iceland the Convention shall apply to the territory of the Republic of Iceland, including any area adjacent to the territorial sea of Iceland within which, under Icelandic law and in accordance with international law, Iceland has sovereign rights for the purpose of exploring and exploiting the natural resources of the sea-bed and sub-soil thereof.

  • ISO-BRITANNIA
    Sitoutumispäivä: 24.01.2008 R
    Voimaantulopäivä: 01.05.2008
    Varauma:

    Article 2

    Annex A - Taxes to which the Convention applies
    For the United Kingdom of Great Britain and Northern Ireland, the Convention shall apply to thoses taxes in Article 2, paragraph 1, which fall within :

    a) any of paragraphs (i) to (iii) of sub-paragraph (a); or
    b) paragraph (iii) of sub-paragraph (b)

    Article 3

    Annex C - Definition of a "national" for the purpose of the Convention
    In relation to the United Kingdom, the term "national" means any British citizen, or any British subject not possessing the citizenship of any other Commonwealth country or territory, provided he has the right of abode in the United Kingdom; and any legal person, partnership, association or other entity deriving its status as such from the laws in force in the United Kingdom.

    Article 30

    Pursuant to Article 30, paragraph 1.a, of the Convention, the United Kingdom will not provide any form of assistance in relation to the taxes of other Parties described in Article 2, paragraph 1.b(i), (ii) or (iv), of the Convention (taxes imposed by or on behalf of political subdivisions or local authorities and social security contributions).

    Article 3

    Annex B - Competent authorities
    In relation to the United Kingdom, the term "competent authority" means the Commissioners for Her Majesty's Revenue and Customs or their authorised representative.

    Article 29

    Pursuant to Article 29, paragraph 1, of the Convention , the United Kingdom declares that with respect to the United Kingdom, the Convention shall apply to Great Britain and Northern Ireland, including any area outside the territorial sea of the United Kingdom designated under its laws concerning the Continental Shelf and in accordance with international law as an area within which the rights of the United Kingdom with respect to the sea bed and subsoil and their natural resources may be exercised. The Convention shall not apply to the Crown Dependencies or any Overseas Territory of the United Kingdom.

    16.5.2014:
    ... ratification of the Convention as amended by its Protocol shall be extended to the territory of the Bailiwick of Guernsey ...
    Pursuant to Article 30, paragraph 1(a), of the Convention, the Government of Guernsey will not provide any form of assistance in relation to the taxes of other Parties described in Article 2, paragraph 1(b), of the Convention.
    Pursuant to Article 30, paragraph 1(b), of the Convention, the Government of Guernsey will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1(c), of the Convention, the Government of Guernsey will not provide assistance in respect of any tax claim, which is in existence at the date of withdrawal of a reservation made under Article 30, paragraph 1(a) or (b), of the Convention, in relation to taxes of the category in question.
    Pursuant to Article 30, paragraph 1(d), of the Convention, the Government of Guernsey will not provide assistance in the service of documents for all taxes listed in Article 2, paragraph 1, of the Convention.
    Pursuant to Article 30, paragraph 1(e), of the Convention, the Government of Guernsey will not permit the service of documents through the post as provided for in Article 17, paragraph 3, of the Convention.
    Annex A - Taxes to which the Convention applies
    For the Bailiwick of Guernsey, the Convention shall apply to those taxes in Article 2, paragraph 1, which fall within paragraphs (a)(i) and (a)(ii).
    Annex B - Competent authorities
    The competent authority for the Bailiwick of Guernsey shall be the Director of Income Tax or his delegate.
    Annex C - Definition of the word "national" for the purpose of the Convention
    In relation to the Bailiwick of Guernsey, the term ???national??? means any individual who has a place of abode in the Bailiwick of Guernsey and possesses British citizenship and any legal person, partnership or association deriving its status as such from the laws in force in the Bailiwick of Guernsey.

  • ISRAEL
    Sitoutumispäivä: 31.08.2016 R
    Voimaantulopäivä: 01.12.2016
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 31 August 2016

    Pursuant to Article 30, paragraph 1.a, of the Convention, the State of Israel reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b, of the Convention:
    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;
    ii. compulsory social security contributions payable to general government or to social security institutions established under public law;
    iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:
    A. estate, inheritance or gift taxes,
    C. general consumption taxes, such as value-added or sales taxes,
    D. specific taxes on goods and services such as excise taxes,
    E. taxes on the use or ownership of motor vehicles,
    F. taxes on the use or ownership of movable property other than motor vehicles,
    G. any other taxes;
    iv. taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the State of Israel will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the State of Israel will not provide assistance in the service of documents for any tax.
    In accordance with Article 9, paragraph 3, of the Convention, Israel will not accept, as a general rule, requests referred to in Article 9, paragraph 1, of the Convention.
    2
    ANNEX A - Taxes to which the Convention would apply.
    Article 2, paragraph 1.a.i:
    ??? the income tax and company tax (including tax on capital gains)
    ??? the tax imposed on gains from the alienation of property according to the Real Estate Taxation Law
    ??? tax imposed under the Petroleum Profits Taxation law
    ANNEX B - Competent authorities
    The Minister of Finance or his authorised representative.

  • ITALIA
    Sitoutumispäivä: 31.01.2006 R
    Voimaantulopäivä: 01.05.2006
    Varauma:

    ANNEX A - Taxes to which the Convention would apply

    Article 2, paragraph 1.a.i- Personal Income Tax (Imposta sul reddito delle persone fisiche - IRPEF);
    - Corporate Income Tax (Imposta sul reddito delle societ?? - IRES and the former Imposta sul reddito delle persone giuridiche - IRPEG).

    Article 2, paragraph 1.a.ii
    - Substitute Income Taxes, irrespective of their denomination.

    Article 2, paragraph 1.b.i
    - Regional Tax on Productive Activities (Imposta regionale sulle attivit?? produttive - IRAP).

    Article 2, paragraph 1.b.iii
    Under category C:
    - Value Added Tax (Imposta sul valore aggiunto - IVA).
    Under category G:
    - Registration Tax (Imposta di registro);
    - Mortgage and Cadastral Taxes (Imposte ipotecaria e catastale).

    Article 2, paragraph 1.b.iv
    - Local Property Tax (Imposta comunale sugli immobili - ICI)

    Article 30, paragraph 1.a

    Italy reserves the right not to provide any form of assistance in relation to taxes of other Parties included in one of the following categories listed in sub paragraph b of paragraph 1 of Article 2 :

    ii. compulsory social security contributions payable to general government or to social security institutions established under public law;

    iii. D. specific taxes on goods and services such as excise taxes,
    E. taxes on the use or ownership of motor vehicles,
    F. taxes on the use or ownership of movable property other than motor vehicles,
    G. any other taxesother than registration tax and mortgage and cadastral taxes.

    iv. taxes in categories D, E, F, G listed in sub paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

    ANNEX B - Competent Authorities

    The Ministry of Economy and Finance - Tax Policy Department.
    Article 30, paragraph 1.b

    Italy reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for the taxes listed in the reservation made under sub-paragraph a above.

    Article 30, paragraph 1.c

    Italy reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Italy or included in the reservation made under sub paragraphs a and b above and existing at the date of withdrawal of such a reservation by Italy.

    Article 30, paragraph 1.d

    Italy reserves the right not to provide assistance in the service of documents for taxes listed the reservation made under sub-paragraph a above.

    Article 30, paragraph 1.e

    Italy reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.

    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

    Considering that Italy has committed to automatically exchange information in/as of 2017 and that, in order to be able to automatically exchange information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax

    Matters (hereafter the ???amended Convention???) in accordance with the timeline to which it has committed, Italy has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the ???CRS MCAA???) on 29 October 2014;

    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for administrative assistance related to taxable periods beginning on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party;

    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may mutually agree that the amended Convention shall have effect for administrative assistance related to earlier taxable periods or charges to tax;

    Mindful that information may only be sent by a jurisdiction under the amended Convention with respect to taxable periods or charges to tax of the receiving jurisdiction for which the amended Convention is in effect and that, as a consequence, sending jurisdictions for which the Convention has newly entered into force in a given year are only in a position to provide administrative assistance to receiving jurisdictions for taxable periods beginning or charges to tax arising on or after 1 January of the following year;

    Acknowledging that an existing Party to the amended Convention would be able to receive information under Article 6 of the amended Convention and the CRS MCAA from a new Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties declare to agree that another date of effect is applicable;

    Further acknowledging that, therefore, a new Party to the amended Convention would be able to send information under Article 6 of the amended Convention and the CRS MCAA to an existing Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if both Parties declare to agree that another date of effect is applicable;

    Recognising that the information received under Article 6 of the amended Convention and the CRS MCAA may lead to follow-up requests by the receiving jurisdiction to the sending jurisdiction, which would relate to the same reporting period for which the sending jurisdiction has automatically exchanged information under the CRS MCAA;

    Confirming that the capacity of a jurisdiction to send CRS-related information under Article 6 of the amended Convention and the CRS MCAA, as well as information relating to follow-up requests pursuant to Article 5 of the amended Convention, shall be governed by the terms of the CRS MCAA, including the relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods or charges to tax of the receiving jurisdiction to which such information relates;

    Italy declares that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between Italy and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction.

    Italy declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between Italy and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, when such assistance concerns follow-up requests related to information exchanged under the CRS MCAA with respect to reporting periods of the sending jurisdiction covered by the CRS MCAA.

  • JAMAIKA
    Sitoutumispäivä: 29.11.2018 R
    Voimaantulopäivä: 01.03.2019
    Varauma:

    ANNEX A ??? Taxes to which the Convention would apply:

    Article 2, paragraph 1.a.i:
    Taxes on income or profits
    Article 2, paragraph 1.a.ii:
    Not applicable
    Article 2, paragraph 1.a.iii:
    Not applicable
    Article 2, paragraph 1.b.i:
    Not applicable
    Article 2, paragraph 1.b.ii:
    The National Insurance Contribution under the National Insurance Act
    Article 2, paragraph 1.b.iii.A:
    Transfer Tax and Stamp Duty
    Article 2, paragraph 1.b.iii.B:
    Property Tax
    Article 2, paragraph 1.b.iii.C:
    General Consumption Tax
    Article 2, paragraph 1.b.iii.D:
    Excise Duty
    Article 2, paragraph 1.b.iii.E:
    Not applicable
    Article 2, paragraph 1.b.iii.F:
    Assets Tax
    Article 2, paragraph 1.b.iii.G:
    Guest Accommodation Room Tax, Minimum Business Tax and Telephone Calls Tax

    ANNEX B ??? Competent Authorities

    The Minister responsible for Finance or his designate, the Commissioner General of Tax Administration of Jamaica, or his designate.

  • JAPANI
    Sitoutumispäivä: 28.06.2013 R
    Voimaantulopäivä: 01.10.2013
    Varauma:

    Article 2

    ANNEX A ??? Taxes to which the Convention would apply

    Pursuant to Article 2, paragraph 2, of the Convention, the Government of Japan declares that the Convention shall apply to those taxes in Article 2, paragraph 1, which fall within:

    Sub-paragraph (a)(i)
    - the income tax
    - the corporation tax
    - the special income tax for reconstruction
    - the special corporation tax for reconstruction

    Sub-paragraph (b)(iii)A
    - the inheritance tax
    - the gift tax

    Sub-paragraph (b)(iii)B
    - the land value tax

    Sub-paragraph (b)(iii)C
    - the consumption tax

    Sub-paragraph (b)(iii)D
    - the liquor tax
    - the tobacco tax
    - the special tobacco tax
    - the gasoline tax
    - the local gasoline tax
    - the liquefied petroleum gas tax
    - the aviation fuel tax
    - the petroleum and coal tax

    Sub-paragraph (b)(iii)E
    - the motor vehicle tonnage tax

    Sub-paragraph (b)(iii)G
    - the registration and license tax
    - the promotion of power-resources development tax
    - the stamp tax
    - the local special corporation surtax

    Article 3

    ANNEX B ??? Competent Authorities

    Pursuant to Article 3, paragraph 1(d), of the Convention, the Government of Japan declares that the term ???competent authority??? means the Minister of Finance or his authorised representative.

    Articles 2, 30

    Pursuant to Article 30, paragraph 1(a), of the Convention, the Government of Japan reserves the right not to provide any form of assistance in relation to the taxes of other Parties in any of the category listed in Article 2, paragraph 1(b)i, ii and iv.
    Pursuant to Article 30, paragraph 1(b), of the Convention, the Government of Japan reserves the right not to provide assistance in the recovery of any tax claim or in the recovery of an administrative fine only for taxes described in Article 2, paragraphs 1(a)(iii), (b)(iii)B, D, E, F and G, of the Convention.

    Articles 4, 5, 7

    Pursuant to Article 4, paragraph 3, of the Convention, the Government of Japan declares that its authorities may inform its resident or national before transmitting information to another Party, in conformity with Article 5 or Article 7 of the Convention.

    **************************'

    Reservations and Declarations

    JAPAN
    Declaration contained in a Note verbale from the Permanent Delegation of Japan to the OECD, dated
    14 December 2020, registered at the Secretariat General of the OECD on 7 January 2021

    Pursuant to paragraph 3 of Article 2 of the Convention on Mutual Administrative Assistance in Tax Matters,
    done at Strasbourg on 25 January 1988 as amended by the Protocol amending the Convention on Mutual
    Administrative Assistance in Tax Matters, done in Paris on 27 May 2010 (hereinafter referred to as the
    "Convention"), the Government of Japan wishes to add "the international tourist tax" to Annex A (Subparagraph (b)(iii)G).
    In addition, pursuant to paragraph 4 of Article 2 of the Convention, the Government of Japan wishes to add
    "the special corporate enterprise tax" to Annex A (Sub-paragraph (b)(iii)G).
    "The special corporate enterprise tax" is a substantially similar tax which is imposed in Japan in addition to
    the existing taxes listed in Annex A within the meaning of paragraph 4 of Article 2 of the Convention. Since
    "the special corporate enterprise tax" has been applied to taxable years on and after October 1, 2019, the
    Convention shall apply to "the special corporate enterprise tax" from the same date.
    The modification of Annex A based on this notification appears as follows:
    Annex A - Taxes to which the Convention would apply:
    Article 2, paragraph 1.b.iii.G:
    - the registration and license tax;
    - the promotion of power-resources development tax;
    - the stamp tax;
    - the local special corporation surtax;
    - the international tourist tax,
    - the special corporate enterprise tax.

  • JORDANIA
    Sitoutumispäivä: 29.09.2020 A
    Voimaantulopäivä: -
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the
    Secretary General of the OECD on 11 August 2021

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Hashemite Kingdom of Jordan reserves the
    right not to provide any form of assistance in relation to the taxes of other Parties included in any of the
    following categories of Article 2, paragraph 1.b:
    i.: taxes on income, profits, capital gains or net wealth which are imposed on behalf of political
    subdivisions or local authorities of a Party;
    iii.: taxes in other categories, except customs duties, imposed on behalf of a Party, namely:
    A. estate, inheritance or gift taxes,
    D. specific taxes on goods and services such as excise taxes,
    E. taxes on the use or ownership of motor vehicles,
    F. taxes on the use or ownership of movable property other than motor vehicles,
    G. any other taxes;
    iv.: taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political
    subdivisions or local authorities of a Party.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Hashemite Kingdom of Jordan reserves the
    right not to provide assistance in the recovery of any tax claim or in the recovery of an administrative fine,
    for all taxes listed in Article 2, paragraph 1, of the Convention.
    The Hashemite Kingdom of Jordan ratifies the Convention on Mutual Administrative Assistance in Tax
    Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in
    Tax Matters, with the following notifications:
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i: Income Tax.
    Article 2, paragraph 1.b.ii: Compulsory social security contributions payable to general government.
    Article 2, paragraph 1.b.iii.B: Jordan Real Estate Tax.
    Article 2, paragraph 1.b.iii.C: Jordan General Sales Tax.
    3 / 3
    ANNEX B ??? Competent Authorities
    The Minister of Finance or his/her authorised representatives.
    The Hashemite Kingdom of Jordan declares that it will apply the provisions of the Convention only in
    respect of the Parties with which it has diplomatic relations.

  • KAP VERDE
    Sitoutumispäivä: 06.01.2020 R
    Voimaantulopäivä: 01.05.2020
    Varauma:

    CABO VERDE
    Reservations and declarations contained in a Note Verbale from the Ministry of Foreign Affairs and Communities of Cabo Verde, dated 27 December 2019,
    accompanying the instrument of ratification deposited with the Secretary General of the OECD on 6 January 2020

    a) In accordance with Article 30, paragraph 1.a of the Convention, the Republic of Cabo Verde will not provide any form of assistance in relation to the taxes of other Parties in any of the categories listed in
    sub-paragraph b. of paragraph 1 of Article 2, except for those mentioned in letters C) and D of paragraph 1.b iii) of Article 2, as included in Annex A;
    b) In accordance with Article 30, paragraph 1.b of the Convention, the Republic of Cabo Verde will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all
    taxes listed in paragraph 1.b of Article 2, except for those mentioned in letters C) and D of paragraph 1.b iii) of Article 2, as included in Annex A;
    c) In accordance with Article 30, paragraph 1.c of the Convention, the Republic of Cabo Verde will not provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the
    Convention in respect of the Republic of Cabo Verde;
    d) In accordance with Article 30, paragraph 1.d of the Convention, the Republic of Cabo Verde will not provide assistance in the service of documents for all taxes listed in paragraph 1.b of Article 2, except for
    those mentioned in letters C) and D of paragraph 1 .b iii) of Article 2, as included in Annex A.

    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i:
    - Personal Income Tax (???Imposto sobre o Rendimento das Pessoas Singulares???)
    - Corporate Income Tax (???Imposto sobre o Rendimento das Pessoas Colectivas???)
    Article 2, paragraph 1.a.ii:
    - Single Property Tax (???Imposto unico sobre o patrimonio, no que diz respeito aos ganhos derivados
    da aliena??ao de bens imobiliarios???)
    Article 2, paragraph 1.b.iii.C:
    - Value Added Tax (???Imposto sobre o Valor Acrescentado???)
    Article 2, paragraph 1.b.iii.D:
    - Special Consumption Tax (???Imposto sobre Consumos Especiais???)
    ANNEX B ??? Competent Authorities
    The Vice-Prime Minister and Minister of Finance, the National Director of State Revenues or their
    authorised representatives.

  • KIINA
    Sitoutumispäivä: 16.10.2015 R
    Voimaantulopäivä: 01.02.2016
    Varauma:

    Pursuant to Article 30, paragraph 1.a, of the Convention, the People??s Republic of China shall not provide any form of assistance in relation to the taxes of other Parties described in sub-paragraphs b.1, b.ii, b.iii A, b.iii.F, and b.iv of paragraph 1 of Article 2.

    Pursuant to Article 30, paragraph 1.b, of the Convention, the People??s Republic of China shall not provide assistance in the recovery of tax claims, or in conservancy measures, for all taxes.

    Pursuant to Article 30, paragraph 1.d, of the Convention, the People??s Republic of China shall not provide assistance in the service of documents for all taxes.

    Pursuant to Article 30, paragraph 1.e, of the Convention, the People??s Republic of China shall not permit the service of documents through the post.

    Pursuant to Article 2, paragraph 1, of the Convention, for the People??s Republic of China, the Convention shall apply to the following taxes imposed under the laws of the People??s Republic of China administered by the tax authority:

    Article 2, paragraph 1.a.i
    - Enterprise Income Tax.
    - Individual Income Tax.

    Article 2, paragraph 1.b.iii.B
    - Urban and Township Land Use Tax.
    - House Property Tax.
    - Land Appreciation Tax.

    Article 2, paragraph 1.b.iii.C
    - Value Added Tax.
    - Business Tax

    Article 2, paragraph 1.b.iii.D
    - Excise Tax.
    - Tobacco Tax.

    Article 2, paragraph 1.b.iii.E
    - Vehicle Purchase Tax.
    - Vehicle and Vessel Tax.

    Article 2, paragraph 1.b.iii.G
    - Resource Tax
    - City Maintenance and Construction Tax.
    - Tax on the Use of Arable Land.
    - Stamp Duty.
    - Deed Tax.

    Pursuant to Article 3, paragraph 1.d, of the Convention, for the People??s Republic of China, the term "competent authority" means the State Administration of Taxation or its authorised representative.

    Pursuant to Article 4, paragraph 3, of the Convention, the People??s Republic of China may inform its resident or national before transmitting information concerning him to another Party, in conformity with Articles 5 and 7 of the Convention.

    Pursuant to Article 29, paragraph 1, of the Convention, unless otherwise notified by the Government of the People??s Republic of China, the Convention shall not apply to the Hong Kong Special Administrative Region and the Macao Special Administrative Region of the People??s Republic of China.

  • KREIKKA
    Sitoutumispäivä: 29.05.2013 R
    Voimaantulopäivä: 01.09.2013
    Varauma:

    Article 2

    ANNEX A ??? Taxes to which the Convention would apply

    Article 2, paragraph 1.a.i:
    ??? Personal income tax;
    ??? Income tax on partnerships;
    ??? Corporate Income tax;
    ??? Withholding tax on dividends, royalties and interests;

    Article 2, paragraph 1.a.ii:
    Tax on profit from the sale of shares;

    Article 2, paragraph 1.a.iii:
    Not applicable;

    Article 2, paragraph 1.b.i:
    Not applicable;

    Article 2, paragraph 1.b.ii
    Compulsory social security contributions payable to general government or to social security institutions, established under public law;

    Article 2, paragraph 1.b.iii.A
    Tax on inheritance gifts and parental provision;

    Article 2, paragraph 1.b.iii.B
    Tax on real estate and
    Special tax on real estate;

    Article 2, paragraph 1.b.iii.C
    Value-added tax;
    Tax on luxury goods;

    Article 2, paragraph 1.b.iii.D
    Special consumption taxes on goods and services such as excise duties;
    Duty on mobile subscription services and on card mobile phone services;
    Insurance tax;
    Tax on casino entrance tickets;
    Special tax on television advertisements;

    Article 2, paragraph 1.b.iii.E
    Road tax on motor vehicles (vignette);
    Registration tax on vehicles;
    Luxury tax on cars;
    Lump sum tax on the registration of public and private use lorries;

    Article 2, paragraph 1.b.iii.F
    Luxury tax on other vehicles e.g. pleasure boats;
    Special tax on private pleasure boats;

    Article 2, paragraph 1.b.iii.G
    Real estate transfer tax;
    Stamp duties;
    Indirect taxes on raising of capital;
    Levy on the tickets of spectacles;
    Tax on playcard game tables in cafes;
    Special tax on bulldozers, cranes etc.;

    Article 2, paragraph 1.b.iv:
    Municipality tax assessed on real estate transfer.

    Article 3

    ANNEX B ??? Competent Authorities

    The Minister of Economy and Finance or his authorised representative.
    For Exchange of Information on Value added taxes : Ministry of Finance, General Secretariat of Taxation and Customs, General Directorate of Tax Audits and Public Revenues, Directorate of Tax Audits, Section B' ??? CLOEL.

    Article 3

    ANNEX C ??? Definition of the term "national" for the purpose of the Convention

    None provided.

    Article 29

    Pursuant to Article 29, paragraph 1, of the Convention, Greece declares that the Convention shall apply to the territory of the Hellenic Republic, including territorial sea and national airspace, as well as to the maritime areas, over which the Hellenic Republic exercises or shall exercise sovereignty, sovereign rights or jurisdiction in accordance with international law.

  • KUWAIT
    Sitoutumispäivä: 17.08.2018 R
    Voimaantulopäivä: 01.12.2018
  • LATVIA
    Sitoutumispäivä: 15.07.2014 R
    Voimaantulopäivä: 01.11.2014
  • LIBANON
    Sitoutumispäivä: 12.05.2017 R
    Voimaantulopäivä: 01.09.2017
    Varauma:

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Lebanon reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the
    categories listed in Article 2, paragraph 1.b, of the Convention.

    Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Lebanon reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

    Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of Lebanon reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Lebanon or, where a reservation has previously been made under subparagraph a or b of paragraph 1 of Article 30 of the Convention, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Lebanon reserves the right not to provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.e, of the Convention, the Republic of Lebanon reserves the right not to permit the service of documents through the post as provided for in Article 17, paragraph 3, of the Convention.

    Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of Lebanon reserves the right to apply paragraph 7 of Article 28 of the Convention exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of Lebanon, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of Lebanon.

    In accordance with Article 4, paragraph 3, of the Convention, the Republic of Lebanon declares that its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7 of the Convention.

    In accordance with Article 9, paragraph 3, of the Convention, the Republic of Lebanon declares that it will not to accept, as a general rule, the requests as referred to in Article 9, paragraph 1, of the
    Convention.

    Pursuant to Article 29, paragraph 1, of the Convention, the Republic of Lebanon hereby declares that the territory to which this Convention applies is the territory of the Republic of Lebanon including its territorial sea as well as the continental shelf as well as the exclusive economic zone over which Lebanon exercises, in accordance with its internal laws and with the international laws, sovereign rights and jurisdiction, for the purpose of exploring and exploiting the natural, biological and mineral resources existing in the sea waters, sea-bed, and subsoil of these waters.

    ANNEX A - Taxes to which the Convention would apply

    Article 2, paragraph 1.a.i:
    ??? the tax on the profits of industrial, commercial and non-commercial professions;
    ??? the tax on salaries, wages and pensions;
    ??? the tax on income derived from movable capital.

    ANNEX B - Competent authorities
    The Minister of Finance or his authorized representative.

    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.
    Considering that the Republic of Lebanon has committed to automatically exchange information in 2018 and that, in order to be able to automatically exchange information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters (hereafter the ???amended Convention???) in accordance with the timeline to which it has committed, the Republic of Lebanon has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the ???CRS MCAA???) on 12 May 2017;

    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for administrative assistance related to taxable periods beginning on or after 1 January of the year following
    the one in which the amended Convention entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party;

    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may mutually agree that the amended Convention shall have effect for administrative assistance related to earlier taxable periods or charges to tax;
    Mindful that information may only be sent by a jurisdiction under the amended Convention with respect to taxable periods or charges to tax of the receiving jurisdiction for which the amended Convention is in effect and that, as a consequence, sending jurisdictions for which the Convention has newly entered into force in a given year are only in a position to provide administrative assistance to receiving jurisdictions for taxable periods beginning or charges to tax arising on or after 1 January of the following year; Acknowledging that an existing Party to the amended Convention would be able to receive information under Article 6 of the amended Convention and the CRS MCAA from a new Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties declare to agree that another date of effect is applicable;

    Further acknowledging that, therefore, a new Party to the amended Convention would be able to send information under Article 6 of the amended Convention and the CRS MCAA to an existing Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if both Parties declare to agree that another date of effect is applicable;

    Recognising that the information received under Article 6 of the amended Convention and the CRS MCAA may lead to follow-up requests by the receiving jurisdiction to the sending jurisdiction, which would relate to the same reporting period for which the sending jurisdiction has automatically exchanged information under the CRS MCAA;

    Confirming that the capacity of a jurisdiction to send CRS-related information under Article 6 of the amended Convention and the CRS MCAA, as well as information relating to follow-up requests pursuant to Article 5 of the amended Convention, shall be governed by the terms of the CRS MCAA, including the relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods or charges to tax of the receiving jurisdiction to which such information relates;

    The Republic of Lebanon declares that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between the Republic of Lebanon and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction.

    The Republic of Lebanon declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between the Republic of Lebanon and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, when such assistance concerns follow-up requests related to information exchanged under the CRS MCAA with respect to reporting periods of the sending jurisdiction covered by the CRS MCAA.

  • LIBERIA
    Sitoutumispäivä: 26.08.2021 R
    Voimaantulopäivä: 01.12.2021
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the
    Secretary General of the OECD on 26 August 2021 - Or. Engl.
    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Liberia will not provide any form
    of assistance in relation to the taxes of other Parties included in the following categories
    Article 2, paragraph 1.b.i
    Article 2, paragraph 1.b iii. A
    Article 2, paragraph 1.b iii. E
    Article 2, paragraph 1.b iii. F
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    - Personal Income Tax
    - Business Income Tax
    - Presumptive Tax
    Article 2, paragraph 1.b.ii: Compulsory Social Security Contribution
    Article 2, paragraph 1.b.iii.B: Real Property Tax
    Article 2, paragraph 1.b.iii.C: Goods and Services Tax
    Article 2, paragraph 1.b.iii.D: Excise Tax
    Article 2, paragraph 1.b.iii.G: Obligatory payments in respect of mining and petroleum operations that are
    construed as taxes under the laws of Liberia
    ANNEX B ??? Competent Authorities
    The Minister of Finance and Development Planning, represented by either the Commissioner General of
    the Liberia Revenue Authority or the Commissioner General???s authorised representative

  • LIECHTENSTEIN
    Sitoutumispäivä: 22.08.2016 R
    Voimaantulopäivä: 01.12.2016
    Varauma:

    Reservations and declarations
    contained in the instrument of ratification and in a Note Verbale from the Office for Foreign Affairs of Liechtenstein, dated 18 August 2016, deposited with the Secretary General of the OECD, on 22 August 2016

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Principality of Liechtenstein reserves the right not to provide any form of assistance in relation to the taxes of other Parties described in any of sub-paragraphs 1(b) (ii), (iii) and (iv) of Article 2 of the Convention.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Principality of Liechtenstein reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes listed in paragraph 1 of Article 2 of the Convention.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Principality of Liechtenstein reserves the right not to provide assistance in the service of documents for all taxes listed in paragraph 1 of Article 2 of the Convention.
    According to Article 30, paragraph 1.f, of the Convention, the Principality of Liechtenstein reserves the right to apply paragraph 7 of Article 28 exclusively:
    a) for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or
    b) where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

    Pursuant to Article 4, paragraph 3, of the Convention, the Principality of Liechtenstein declares that its competent authority may inform its resident or national before transmitting information concerning him to another Party, in conformity with Articles 5 and 7 of the Convention.
    Pursuant to Article 9, paragraph 3, of the Convention, the Principality of Liechtenstein declares that it will, as a general rule, not accept requests to allow representatives of the competent authority of the applicant State to be present at the appropriate part of a tax examination in Liechtenstein.

    ANNEX A - Taxes to which the Convention would apply.
    Article 2, paragraph1.a (i):
    - Personal Income Tax (Erwerbssteuer)
    - Corporate Income Tax (Ertragssteuer)
    Article 2, paragraph1.a (ii):
    - Real Estate Capital Gains Tax (Grundst??cksgewinnsteuer)
    Article 2, paragraph1.a (iii):
    - Wealth Tax (Verm??genssteuer)
    ANNEX B - Competent authorities
    In relation to the Principality of Liechtenstein, the term ???competent authority??? means the Fiscal Authority.
    ANNEX C - Definition of the term "national" for the purpose of the Convention
    In relation to the Principality of Liechtenstein, the term "national" means:
    (i) any individual possessing the nationality or citizenship of Liechtenstein; and
    (ii) any person other than an individual deriving its status as such from the laws in force in Liechtenstein.

  • LIETTUA
    Sitoutumispäivä: 04.02.2014 R
    Voimaantulopäivä: 01.06.2014
    Varauma:

    Declarations 8 April 2014, registered at the Secretariat General on 15 May 2014
    Annex A - Taxes to which the Convention applies
    In relation to the Republic of Lithuania, the Convention shall apply to taxes in all categories referred to in paragraph 1(a) and 1(b) of Article 2 of the Convention, which correspond to the taxes listed in Article 13 of the Law on Tax Administration of the Republic of Lithuania of the year 2004 (No. IX-2112), as amended.
    Annex B - Competent authorities
    In relation to the Republic of Lithuania, the term ???competent authority??? means the State Tax Inspectorate under the Ministry of Finance.
    Annex C - Definition of the word "national" for the purpose of the Convention
    In relation of the Republic of Lithuania, the term ???national??? means all individuals possessing the citizenship of the Republic of Lithuania, and all legal persons, partnerships, associations or other entities deriving their status as such from the laws in force in the Republic of Lithuania.

  • LUXEMBURG
    Sitoutumispäivä: 11.07.2014 R
    Voimaantulopäivä: 01.11.2014
  • MALEDIIVIT
    Sitoutumispäivä: 20.09.2021 R
    Voimaantulopäivä: 01.01.2022
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the
    Secretary General of the OECD on 20 September 2021

    In accordance with Article 30, paragraph 1.b, of the Convention, Maldives reserves the right to not provide
    assistance in the recovery of any tax claim, including measures of conservancy, or in the recovery of an
    administrative fine, for all taxes.
    In accordance with Article 30, paragraph 1.f, of the Convention, Maldives reserves the right to apply
    Article 28, paragraph 7, exclusively for administrative assistance related to taxable periods beginning on
    or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010
    Protocol, entered into force in respect of Maldives, or where there is no taxable period, for administrative
    assistance related to charges to tax arising on or after 1 January of the third year preceding the one in
    which the Convention, as amended by the 2010 Protocol, entered into force in respect of Maldives.

    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    - Income Tax imposed under the Income Tax Act (Law Number 25/2019).
    Article 2, paragraph 1.b.iii.C:
    - Goods and Services Tax imposed under the Goods and Services Act (Law Number 10/2011).
    ANNEX B ??? Competent Authorities
    The Commissioner General of Taxation or their authorised representative.
    ANNEX C ??? Definition of the term ???national??? for the purposes of the Convention
    (i) any individual possessing the nationality or citizenship of Maldives;
    (ii) any legal person, partnership or association deriving its status as such from the laws in force
    in Maldives.
    In accordance with Article 29, paragraph 1, of the Convention, Maldives declares that the Convention
    shall apply to all parts of the territory of the Maldives and includes its territorial sea, continental shelf, seabed, sub-soil (and their natural resources) and airspace, as well as any maritime zone in which the
    Maldives has sovereign rights, other rights and jurisdiction, according to the law of the Maldives and in
    accordance with international law, including the United Nations Convention on the Law of the Sea.

  • MALESIA
    Sitoutumispäivä: 03.01.2017 R
    Voimaantulopäivä: 01.05.2017
  • MALTA
    Sitoutumispäivä: 29.05.2013 R
    Voimaantulopäivä: 01.09.2013
    Varauma:

    Article 30

    In relation to Article 30, paragraph 1.a:
    Malta reserves the right not to provide any form of assistance in relation to taxes of other Parties included in one of the following categories listed in sub-paragraphs b.ii, b.iii and b.iv of paragraph 1 of Article 2 of the Convention:

    Sub-paragraph ii: compulsory social security contributions payable to general government or to social security institutions established under public law;

    Sub-paragraph iii:
    A. estate, inheritance or gift taxes,
    B. taxes on immovable property,
    D. specific taxes on goods and services such as excise taxes,
    E. taxes on the use or ownership of motor vehicles,
    F. taxes on the use or ownership of movable property other than motor vehicles,
    G. any other taxes.

    Sub-paragraph iv: taxes in categories A, B, D, E, F and G listed in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.


    In relation to Article 30, paragraph 1.b:
    Malta reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes listed in paragraph 1 of Article 2 of the Convention except for the categories listed in sub-paragraphs a.i and a.ii of that paragraph 1.

    In relation to Article 30, paragraph 1.c:
    Malta reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Malta and, due to the reservations in relation to paragraphs 1.a and 1.b of Article 30 of the Convention, to any existing tax claim at the date of withdrawal of such a reservation by Malta.

    In relation to Article 30, paragraph 1.d:
    Malta reserves the right not to provide assistance in the service of documents for taxes listed in paragraph 1 of Article 2 of the Convention except for the categories listed in subparagraph a.i and a.ii of that paragraph 1.

    Article 2

    Annex A ??? Taxes to which the Convention would apply:

    In relation to Article 2, paragraph 2, of the Convention (and for the purposes of Annex A to the Convention), Malta declares that in its case the Convention applies to the following taxes as listed in paragraphs 1.a and 1.b of the said Article 2:

    Article 2, paragraph 1.a:

    i.: Tax imposed under the Income Tax Act
    ii.: Not applicable
    iii.: Not applicable

    Article 2, paragraph 1.b:

    i.: Not applicable
    ii.: Not applicable
    iii. A: Not applicable
    iii. B: Not applicable
    iii. C: Tax imposed under the Value Added Tax Act
    iii. D: Not applicable
    iii. E: Not applicable
    iii. F: Not applicable
    iii. G: Not applicable
    iv.: Not applicable

    Article 3

    ANNEX B ??? Competent Authorities

    In relation to Article 3, paragraph 1.d, of the Convention (and for the purposes of Annex B to the Convention), Malta declares that the competent authority will be the Minister responsible for finance or his authorised representative.

  • MAROKKO
    Sitoutumispäivä: 22.05.2019 R
    Voimaantulopäivä: 01.09.2019
    Varauma:

    Pursuant to Article 30, paragraph 1.a, of the Convention, Morocco reserves the right not to provide any form of assistance in relation to the taxes of other Contracting Parties included in any of the categories listed in Article 2, paragraph 1.b.
    Period covered: 01/09/2019 -
    Articles concerned : 30

  • MARSHALLINSAARET
    Sitoutumispäivä: 22.12.2016 R
    Voimaantulopäivä: 01.04.2017
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 22 December 2016:

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of the Marshall Islands reserves the right not to provide any form of assistance in relation to the taxes of other Parties in any of the categories listed in sub-paragraph b of paragraph 1 of Article 2, provided that it has not included any domestic tax in that category under Annex A of the Convention.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of the Marshall Islands reserves the right not to provide assistance in the recovery of any tax claim, or the recovery of an administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of the Marshall Islands reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of the Republic of the Marshall Islands.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of the Marshall Islands reserves the right not to provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of the Marshall Islands reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    Taxes imposed under the Income Tax Act 1989
    Article 2, paragraph 1.b.ii:
    Taxes imposed under the Social Security Act of 1990
    Article 2, paragraph 1.b.iii.B:
    Tax on land lease payments
    Article 2, paragraph 1.b.iii.G:
    Hotel and Resort Tax

    ANNEX B - Competent authorities
    The Secretary of Finance or his authorised representative.

    Declaration accompanying the instrument of ratification registered at the Secretariat General of the OECD on 22 December 2016

    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.
    Considering that the Republic of the Marshall Islands has committed to automatically exchange information as of 2018 and that, in order to be able to automatically exchange information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters (hereafter the ???amended Convention???) in accordance with the timeline to which it has committed, the Republic of the Marshall Islands has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the ???CRS MCAA???) on 29 October 2015;
    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for administrative assistance related to taxable periods beginning on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party;
    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may mutually agree that the amended Convention shall have effect for administrative assistance related to earlier taxable periods or charges to tax;
    Mindful that information may only be sent by a jurisdiction under the amended Convention with respect to taxable periods or charges to tax of the receiving jurisdiction for which the amended Convention is in effect and that, as a consequence, sending jurisdictions for which the Convention has newly entered into force in a given year are only in a position to provide administrative assistance to receiving jurisdictions for taxable periods beginning or charges to tax arising on or after 1 January of the following year;
    Acknowledging that an existing Party to the amended Convention would be able to receive information under Article 6 of the amended Convention and the CRS MCAA from a new Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties declare to agree that another date of effect is applicable;
    Further acknowledging that, therefore, a new Party to the amended Convention would be able to send information under Article 6 of the amended Convention and the CRS MCAA to an existing Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if both Parties declare to agree that another date of effect is applicable;
    Recognising that the information received under Article 6 of the amended Convention and the CRS MCAA may lead to follow-up requests by the receiving jurisdiction to the sending jurisdiction, which would relate to the same reporting period for which the sending jurisdiction has automatically exchanged information under the CRS MCAA;
    Confirming that the capacity of a jurisdiction to send CRS-related information under Article 6 of the amended Convention and the CRS MCAA, as well as information relating to follow-up requests pursuant to Article 5 of the amended Convention, shall be governed by the terms of the CRS MCAA, including the relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods or charges to tax of the receiving jurisdiction to which such information relates;
    The Republic of the Marshall Islands declares that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between the Republic of the Marshall Islands and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction.
    The Republic of the Marshall Islands declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between the Republic of the Marshall Islands and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, when such assistance concerns follow-up requests related to information exchanged under the CRS MCAA with respect to reporting periods of the sending jurisdiction covered by the CRS MCAA.

  • MAURITANIA
    Sitoutumispäivä: 29.04.2022 R
    Voimaantulopäivä: 01.08.2022
    Varauma:

    Declarations contained in the instrument of ratification deposited with the Secretary General of the
    OECD on 29 April 2022

    Mauritania ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by
    the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters with the
    following notifications:
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    . Tax on Industrial and Commercial Profits (IBIC)
    . Tax on non-Commercial Profits (IBNC)
    . Agricultures Profits Tax (IBA)
    . Minimum Fixed Tax (IMF)
    . Tax on salaries, wages, pensions and life annuities (ITS)
    Article 2, paragraph 1.a.ii: Tax on Income from Movable Assets (IRCM)
    Article 2, paragraph 1.b.iii.B: Property Income Tax (IRF)
    Article 2, paragraph 1.b.iii.C:
    . Value-added Tax (VAT)
    . Tax on Financial Transactions (TOF)
    Article 2, paragraph 1.b.iii.G: Apprenticeship Tax (TA).
    ANNEX B ??? Competent Authorities
    The Minister of Finance or his authorised representative.
    ANNEX C - Definition of the word "national" for the purpose of the Convention
    All individuals possessing the Mauritanian nationality and all legal persons, partnerships, associations
    and other entities provided for and deriving their status as such from the laws in force in the Islamic
    Republic of Mauritania.

  • MEKSIKO
    Sitoutumispäivä: 23.05.2012 R
    Voimaantulopäivä: 01.09.2012
    Varauma:

    Article 2

    ANNEX A - Taxes to which the Convention would apply:

    Article 2, paragraph 1, sub-paragraph a (i):
    . Income Tax and Flat Rate Corporate Tax.

    Article 2, paragraph 1, sub-paragraph b (iii) C:
    . Value Added Tax.

    Article 2, paragraph 1, sub-paragraph b (iii) D:
    Special Tax on Production and Services.

    Article 3

    ANNEX C - Definition of the word ???national??? for the purpose of the Convention

    The term ???national??? means:

    (i) any individual of Mexican nationality ; and
    (ii) any legal entity, company or association that derives its status as such from the current legislation in Mexico.

    Article 30

    In accordance with sub-paragraph a. of paragraph 1 of Article 30 of the Convention, Mexico will not provide any type of assistance in relation to the taxes of other Parties described in sub-paragraph b. (i), (ii), (iii) A, B, E, F and G or (iv) of paragraph 1 of Article 2 of the Convention.

    In accordance with sub-paragraph b. of paragraph 1 of Article 30 of the Convention, Mexico will not provide assistance in the recovery of any tax claim or in the recovery of an administrative fine, for taxes described in sub-paragraph b. (i), (ii), (iii), A, B, E, F and G or (iv) of paragraph 1 of Article 2 of the Convention.

    In accordance with sub-paragraph d. of paragraph 1 of Article 30 of the Convention, Mexico will not provide assistance in the service of documents for the taxes described in sub-paragraph b. (i), (ii), (iii), A, B, E, F and G or (iv) of paragraph 1 of Article 2 of the Convention.

    In accordance with sub-paragraph e. of paragraph 1 of Article 30 of the Convention, Mexico will not permit the service of documents through the post as provided for in paragraph 3 of Article 17, with respect to the taxes described in sub-paragraph b. (i), (ii), (iii), A, B, E, F and G or (iv) of paragraph 1 of Article 2 of the Convention.

    Article 3

    ANNEX B - Competent Authorities

    . Ministry of Finance;
    . Tax Administration Service.

  • MOLDOVA
    Sitoutumispäivä: 24.11.2011 R
    Voimaantulopäivä: 01.03.2012
  • MONACO
    Sitoutumispäivä: 14.12.2016 R
    Voimaantulopäivä: 01.04.2017
  • MONGOLIA
    Sitoutumispäivä: 19.02.2020 R
    Voimaantulopäivä: 01.06.2020
    Varauma:

    MONGOLIA
    Reservations and declarations contained in the instrument of ratification deposited with the Secretariat General of the OECD on 19 Febryary 2020

    Pursuant to Article 30, paragraph 1.a, of the Convention, Mongolia reserves the right not to provide any form of assistance in relation to the taxes included in any of the following categories listed in Article 2, paragraph 1.b:
    i. Taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;
    ii. Compulsory social security contributions payable to general government or to social security institutions established under public law, and
    iii. Taxes in other categories, except customs duties, imposed on behalf of a Party, namely:
    A Estate, inheritance or gift taxes,
    B Taxes on immovable property,
    C General consumption taxes, such as value-added or sales taxes,
    D Specific taxes on goods and services such as excise taxes,
    E Taxes on the use or ownership of motor vehicles,
    F Taxes on the use or ownership of movable property other than motor vehicles,
    G Any other taxes.
    Pursuant to Article 30, paragraph 1.b, of the Convention, Mongolia reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes listed in Article 2, paragraph 1.b, of the Convention.
    Pursuant to Article 30, paragraph 1.c, of the Convention, Mongolia reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made under sub-paragraph a or b above, at the date of withdrawal of such a reservation in relation to taxes in the category in question.
    Pursuant to Article 30, paragraph 1.d, of the Convention, Mongolia reserves the right not to provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.e, of the Convention, Mongolia reserves the right not to permit the service of documents through the post as provided for in Article 17, paragraph 3.

    Pursuant to Article 30, paragraph 1.f, of the Convention, Mongolia reserves the right not to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.
    Mongolia ratifies the Convention with the following notifications:
    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i:
    - Corporate Income Tax,
    - Personal Income Tax.
    ANNEX B ??? Competent Authorities
    In relation to Mongolia, the term ???competent authorities??? means the Minister of Finance, Commissioner of General tax Department and their authorised representative.
    ANNEX C ??? Definition of the term ???national??? for the purpose of the Convention
    In relation to Mongolia, the term ???national??? means any individual possessing the citizenship of Mongolia; and any legal person, company, partnership or association deriving its status as such from the law in force in Mongolia.

  • MONTENEGRO
    Sitoutumispäivä: 28.01.2020 R
    Voimaantulopäivä: 01.05.2020
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 28 January 2020., clarified by a Note verbale from the Ministry of Foreign Affairs of Montenegro, dated 17 February 2020, registered at the Secretariat General of the OECD on 27 February 2020

    Pursuant to Article 30, paragraph 1.a, of the Convention, Montenegro reserves the right not to provide any kind of assistance in respect of taxes of other Parties in any of the categories listed in Article 2, paragraph 1.b, of the Convention, provided that domestic taxes in that category and are not included in Annex A to the Convention.
    Pursuant to Article 30, paragraph 1.b, of the Convention, Montenegro reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of any administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1.c, of the Convention, Montenegro reserves the right not to provide assistance in connection with any tax claim existing at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made in accordance with sub-paragraph a or b of this Convention, on the date of withdrawal of such a reservation in respect of taxes in the relevant category.
    Pursuant to Article 30, paragraph 1.d, of the Convention, Montenegro reserves the right not to provide assistance in the service of documents for all taxes listed in Article 2, paragraph 1, of the Convention.
    Pursuant to Article 30, paragraph 1.f, of the Convention, Montenegro reserves the right not to apply paragraph 7 of Article 28 of this Convention exclusively for administrative assistance relating to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i:
    - Personal Income Tax;
    - Corporate Income Tax.
    ANNEX B ??? Competent Authorities
    The Ministry of Finance or its authorised representative.

    In accordance with Article 4, paragraph 3, of the Convention, Montenegro declares that, according to its domestic legislation, its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7 of this Convention.
    In accordance with Article 9, paragraph 3, of the Convention, Montenegro informs of its intention not to accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the Convention.

  • NAMIBIA
    Sitoutumispäivä: 09.12.2020 R
    Voimaantulopäivä: 01.04.2021
    Varauma:

    NAMIBIA
    Declarations contained in the instrument of ratification deposited with the Secretariat General
    of the OECD on 9 December 2020

    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i:
    - Income tax;
    - Withholding tax on royalties;
    - Withholding tax on management fees;
    - Withholding tax on interest;
    - Withholding tax on dividends.
    Article 2, paragraph 1.b.iii.B: Transfer Duty.
    Article 2, paragraph 1.b.iii.C: Value Added Tax.
    Article 2, paragraph 1.b.iii.E: Excise Tax.
    ANNEX B ??? Competent Authorities
    The Minister of Finance or his authorised representative.

  • NAURU
    Sitoutumispäivä: 28.06.2016 A
    Voimaantulopäivä: -
    Varauma:

    Declaration transmitted by the Department of Foreign Affairs and Trade of the Republic of Nauru to the Secretariat General of the OECD on 15 February 2017 - Or. Engl.

    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

    Considering that Nauru has committed to automatically exchange information as of 2018 and that, in order to be able to automatically exchange information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters (hereafter the ???amended Convention???) in accordance with the timeline to which it has committed, Nauru has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the ???CRS MCAA???) on 28 June 2016;

    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for administrative assistance related to taxable periods beginning on or after 1 January of the year following
    the one in which the amended Convention entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party;

    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may mutually agree that the amended Convention shall have effect for administrative assistance related to earlier taxable periods or charges to tax;

    Mindful that information may only be sent by a jurisdiction under the amended Convention with respect to taxable periods or charges to tax of the receiving jurisdiction for which the amended Convention is in effect and that, as a consequence, sending jurisdictions for which the Convention has newly entered into force in a given year are only in a position to provide administrative assistance to receiving jurisdictions for taxable periods beginning or charges to tax arising on or after 1 January of the following year;

    Acknowledging that an existing Party to the amended Convention would be able to receive information under Article 6 of the amended Convention and the CRS MCAA from a new Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties declare to agree that another date of effect is applicable;

    Further acknowledging that, therefore, a new Party to the amended Convention would be able to send information under Article 6 of the amended Convention and the CRS MCAA to an existing Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if both Parties declare to agree that another date of effect is applicable;

    Recognising that the information received under Article 6 of the amended Convention and the CRS MCAA may lead to follow-up requests by the receiving jurisdiction to the sending jurisdiction, which would relate to the same reporting period for which the sending jurisdiction has automatically exchanged information under the CRS MCAA;

    Confirming that the capacity of a jurisdiction to send CRS-related information under Article 6 of the amended Convention and the CRS MCAA, as well as information relating to follow-up requests pursuant to Article 5 of the amended Convention, shall be governed by the terms of the CRS MCAA, including the relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods or charges to tax of the receiving jurisdiction to which such information relates;

    Nauru declares that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between Nauru and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction.

    Nauru declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between Nauru and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, when such assistance concerns follow-up requests related to information exchanged under the CRS MCAA with respect to reporting periods of the sending jurisdiction covered by the CRS MCAA.

  • NIUE
    Sitoutumispäivä: 06.06.2016 R
    Voimaantulopäivä: 01.10.2016
    Varauma:

    Declarations:

    Annex A
    Article 2, paragraph 1.a.i:
    Taxes on income or progits
    Article 2, paragraph 1.a.ii:
    Taxes on capital gains which are imposed separately from the tax on income or profits
    Article 2, paragraph 1.a.iii:
    Taxes on net wealth
    Article 2, paragraph 1.b.iii:
    Taxes in other categories, except customs duties, imposed on behalf of a Party, namely:
    Article 2, paragraph 1.b.iii.A:
    Estate, inheritance or gift taxes
    Article 2, paragraph 1.b.iii.C:
    General consumption taxes, such as value-added or sales taxes
    Article 2, paragraph i.b.iii.D:
    Specific taxes on goods and services such as excise taxes
    Article 2, paragraph 1.b.iii.G:
    Any other taxes.

    Annex B
    In relation to Niue, the tem "competent authority" means the Financial Secretary of the Department of Finance and Planning or an authorized representative of the Financial Secretary.

    Annex C
    Any individual belonging to the aboriginal race of Niue or possessing permanent resident status in Niue and any legal person, partnership or associations deriving its status as such from the laws in force in Niue.

  • NORJA
    Sitoutumispäivä: 13.06.1989
    Voimaantulopäivä: 01.04.1995
    Varauma:

    As regards Norway the Convention on Mutual Administrative Assistance in Tax Matters shall apply to the territory of the Kingdom of Norway, including any area outside the territorial waters of the Kingdom of Norway, where the Kingdom of Norway, according to Norwegian legislation and in accordance with international law, may exercise her rights with respect to the seabed and subsoil and their natural resources; the Convention does not apply to Svalbard, Jan Mayen or the Norwegian dependencies ("biland").

    ANNEX A

    Article 2, paragraph 1.a:

    1. the national tax on income (inntektsskatt til staten)

    the national dues on remuneration to non-resident artists (avgift til staten av honorarer som tilfaller kunstnere bosatt i utlandet)

    2. the national tax on capital gains from the alienation of shares (skatt til staten av gevinst ved avhendelse av aksjer)

    3. the national tax on capital (formuesskatt til staten)

    Article 2, paragraph 1.b:

    1. the county municipal tax on income (inntektsskat til fylkeskommunen)
    the municipal tax on income (inntektsskat til kommunen)
    the municipal tax on capital (formuesskatt til kommunen)
    the national contributions to the Tax Equalisation Fund (fellesskatt til Skattefordelingsfondet)

    2. contributions to the National Insurance Scheme (folketrygdavgift)

    3. A. tax on inheritance and certain gifts (avgift p? arv og visse gaver)

    B. -

    C. value added tax (merverdiavgift)
    investment tax (investeringsavgift)

    D. taxes and excises on :
    alcoholic beverages (brennevin og vin m.v.)
    alcohol in imported essences (alkohol i essenser som inf?res)
    beer (?l)
    tobacco (tobakksvarer)
    petrol (bensin)
    petroleum (mineralolje)
    lubricants (sm?reolje)
    marine engines (b?tmotorer)
    electric power (elektrisk kraft)
    chocolates and sweets (sjokolade)
    sugar (sukker)
    non-alcoholic beverages (alkoholfrie drikkevarer)
    air-charter travel (charterreiser med fly)
    cosmetic toiletries (kosmetiske toalettmidler)
    equipment for recording and reproduction of sound and pictures etc. (utstyr for opptak og gjengivelse av lyd og bilde m.v.)
    unrecorded audiotapes as well as recorded and unrecorded videotapes (uinnspilte lydkassettb?nd og innspilte og uinnspilte videokassettb?nd)
    radio and television equipment (radio og televisjonsmateriell)
    non-returnable bottles (engangsflasker)
    batteries hazardous to the environment (milj?skadelige batterier)

    E. annual tax on motor vehicles (?rsavgift p? motorvogner)
    tax on motor vehicles etc. (engangsavgift p? motorvogner m.v.)
    mileage tax on the use of diesel-powered vehicles (kilometeravgift)
    reregistration tax (omregistreringsavgift)
    tax on assembled motor vehicles (oppbyggingsavgift)

    F. tax on the registration of caravans (avgift p? f?rstegangs registrering av campingtilhengere)
    annual tax on caravans (?rsavgift p? campingtilhengere)

    G. tax on documents transferring title to real property (avgift p? dokument som overf?rer hjemmel til fast eiendom)
    tax on the transfer of ownership rights and rights of use to real property etc. abroad (avgift p? overf?ring av eiendomsrett og bruksrett til fast eiendom m.v. i utlandet)

    4. municipal tax on real property (eiendomsskatt til kommunen)

    ANNEX B

    The Minister of Finance and Customs or his authorised representative.

  • OMAN
    Sitoutumispäivä: 07.07.2020 R
    Voimaantulopäivä: 01.11.2020
    Varauma:

    Reservations and declarations contained in a Note Verbale from the Embassy of the Sultanate
    of Oman in Paris, accompanying the instrument of ratification
    registered at the Secretariat General of the OECD on 7 July 2020

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Sultanate of Oman reserves the right not to
    provide any form of assistance in relation to the taxes of other Parties included in any of the categories
    listed in Article 2, paragraph 1.b, of the Convention.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Sultanate of Oman reserves the right not to
    provide assistance in the recovery of any tax claim, or the recovery of an administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Sultanate of Oman reserves the right not to
    provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1 .f, of the Convention, the Sultanate of Oman reserves the right to
    apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods
    beginning on or after 1 January of the third year preceding the one in which the Convention, as amended
    by the 2010 Protocol, entered into force in respect of the Sultanate of Oman, or where there is no taxable
    period, for administrative assistance related to charges to tax arising on or after 1 January of the third
    year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in
    respect of the Sultanate of Oman.
    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph l.a.i:
    - Income tax (28/2009)
    ANNEX B ??? Competent Authorities
    The Chairman of the Tax Authority

  • PAKISTAN
    Sitoutumispäivä: 14.12.2016 R
    Voimaantulopäivä: 01.04.2017
  • PANAMA
    Sitoutumispäivä: 16.03.2017 R
    Voimaantulopäivä: 01.07.2017
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 16 March 2017:

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Panama reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in one of the following categories listed in Article 2, paragraph 1.b.

    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political
    subdivisions or local authorities of a Party;
    ii. compulsory social security contributions payable to general government or to social security
    institutions established under public law, and
    iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

    A. estate, inheritance or gift taxes,
    B. taxes on immovable property,
    C. general consumption taxes, such as value-added or sales taxes,
    D. specific taxes on goods and services such as excise taxes,
    E. taxes on the use or ownership of motor vehicles,
    F. taxes on the use or ownership of movable property other than motor vehicles,
    G. any other taxes.

    iv. taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party. Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Panama reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine for all taxes listed in Article 2, paragraph 1.
    Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of Panama reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made under subparagraph a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Panama reserves the right not to provide assistance in the service of documents for all taxes listed in Article 2, paragraph 1.
    Pursuant to Article 30, paragraph 1.e, of the Convention, the Republic of Panama reserves the right not to permit the service of documents through the post as provided for in Article 17, paragraph 3.
    Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of Panama reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

    The Republic of Panama, in accordance with Article 9, paragraph 3, of the Convention, declares its intention not to accept, as a general rule, the requests as are referred to in paragraph 1 of Article 9 of the Convention.

    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.:
    i. Taxes on income of profits (provided in the Tax Code, Book IV, Title I, and the applicable decrees
    and regulations),
    ii. Taxes on capital gains which are imposed separately from the tax on income or profits (provided
    in the Tax Code, Book IV, Title I, and the applicable decrees and regulations).

    ANNEX B - Competent authorities
    The Ministry of Economy and Finances or its authorised representative.

    ANNEX C - Definition of the word "national" for the purpose of the Convention
    The term ???national??? means any physical person possessing the Panamanian nationality and any legal
    person, partnership or association organised under the laws in force in Panama.

  • PAPUA-UUSI-GUINEA
    Sitoutumispäivä: 11.08.2021 A
    Voimaantulopäivä: -
  • PARAGUAY
    Sitoutumispäivä: 15.07.2021 R
    Voimaantulopäivä: 01.11.2021
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the
    Secretary General of the OECD on 15 July 2021

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Paraguay will not provide any
    form of assistance in relation to the taxes of other Parties mentioned in the following categories of
    Article 2, paragraph 1:
    Article 2, paragraph 1.b.i;
    Article 2, paragraph 1.b.ii;
    Article 2, paragraph 1.b.iii.A;
    Article 2, paragraph 1.b.iii.B;
    Article 2, paragraph 1.b.iii.E;
    Article 2, paragraph 1.b.iii.F;
    Article 2, paragraph 1.b.iii.G, and
    Article 2, paragraph 1.b.iv.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Paraguay will not provide
    assistance in the recovery of any tax claim or in the recovery of administrative fines for all taxes.
    Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of Paraguay reserves the right not
    to provide assistance in relation to any tax claim that exists at the date of entry into force of the Convention
    in respect of that State or, in the event that a reservation has been previously formulated by virtue of
    Article 30, paragraphs 1.a or b, at the date of withdrawal of such a reservation in relation to taxes in the
    category in question.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Paraguay will not provide
    assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.e, of the Convention, the Republic of Paraguay reserves the right not
    to permit service of documents through the post as provided for in Article 17, paragraph 3.
    Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of Paraguay reserves the right to
    apply Article 28, paragraph 7, exclusively for administrative assistance related to taxable periods
    beginning on or after 1 January of the third year preceding the one in which the Convention, as amended
    by the 2010 Protocol, entered into force in respect of the Republic of Paraguay, or where there is no
    taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the
    The Republic of Paraguay ratifies the Convention on Mutual Administrative Assistance in Tax Matters as
    amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters,
    with the following notifications:
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    - Business Income Tax (Impuesto a la Renta Empresarial ??? IRE);
    - Tax on dividends and profits (Impuesto a los dividendos y a las utilidades ??? IDU);
    - Personal Income Tax (Impuesto a la Renta Personal ??? IRP);
    - Non-Resident Income tax (Impuesto a la Renta de No Residentes ??? INR).
    Article 2, paragraph 1.b.iii.C: Value Added Tax (Impuesto al Valor Agregado ??? IVA).
    Article 2, paragraph 1.b.iii.D: Selective Consumption Tax (Impuesto Selectivo al Consumo ??? ISC).
    ANNEX B ??? Competent Authorities
    The Republic of Paraguay declares that the competent authority, with the powers mentioned in Article 3,
    paragraph 1.d, of the Convention is the Minister of Finance, the Undersecretary of State for Taxation and
    their authorised representatives.
    In accordance with Article 4, paragraph 3, of the Convention, the Republic of Paraguay may inform its
    resident or national before transmitting information concerning him to a Party in accordance with
    Articles 5 and 7 of the Convention.
    In accordance with Article 9, paragraph 3, of the Convention, the Republic of Paraguay declares that, as
    a general rule, it will not accept requests to allow representatives of the competent authority of the
    applicant State to be present at the appropriate part of a tax examination in the Republic of Paraguay.
    In accordance with Article 29 of the Convention, the Republic of Paraguay declares that the Convention
    will apply to the territorial extension over which the State exercises its sovereignty or jurisdiction in
    accordance with its Constitution, international law and the laws.
    third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into
    force in respect of the Republic of Paraguay

  • PERU
    Sitoutumispäivä: 28.05.2018 R
    Voimaantulopäivä: 01.09.2018
  • POHJOIS-MAKEDONIA
    Sitoutumispäivä: 30.09.2019 R
    Voimaantulopäivä: 01.01.2020
    Varauma:

    Reservations and Declarations contained in the instrument of ratification deposited with the Secretariat General of the Council of Europe on 30 September 2019

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of North Macedonia reserves the right not to provide any form of assistance in relation to the taxes of other Parties to the Convention in any of the categories listed in Article 2, paragraph 1.b, of the Convention, provided that it has not included any domestic tax in that category under Annex A of the Convention:
    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;
    iii. taxes in other categories, except custom duties, imposed on behalf of a Party, namely:
    A. estate, inheritance or gift taxes,
    B. taxes on immovable property;
    E. taxes on the use or ownership of motor vehicles;
    F. taxes on the use or ownership of movable property other than motor vehicles;
    G. any other taxes;
    vi. taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of North Macedonia reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for taxes listed in the reservation made under Article 30, paragraph 1.a, of the Convention.
    Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of North Macedonia reserves the right not to provide assistance in respect of any tax claim which is in existence at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made under Article 30, paragraph 1.a or b, at the date of withdrawal of such a reservation by the Republic of North Macedonia in relation to taxes in the category in question.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of North Macedonia reserves the right not to provide assistance in the service of documents for the taxes in the reservation made under Article 30, paragraph 1.a, of the Convention.
    3 / 5
    Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of North Macedonia reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of North Macedonia, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of North Macedonia.
    Annex A - Taxes to which the Convention would apply
    Pursuant to Article 2, paragraph 2, of the Convention (for the purposes of Annex A of the Convention), the Republic of North Macedonia declares that the Convention shall apply to those taxes in Article 2, paragraph 1, of the Convention which fall within:
    Article 2, paragraph 1.a.i:
    . Personal Income Tax (?????????? ???? ?????????? ??????????);
    . Corporate Income Tax (????????????????????????????).
    Article 2, paragraph 1.b.ii:
    . Compulsory Social Security Contribution (?????????????????? ???? ?????????????????????????? ?????????????????? ??????????????????????).
    Article 2, paragraph 1.b.iii.C:
    . Value Added Tax (?????????? ???? ???????????????? ????????????????).
    Article 2, paragraph 1.b.iii.D:
    . Excise (????????????).
    Annex B - Competent authorities
    Pursuant to Article 3, paragraph 1.d, of the Convention (for the purposes of Annex B of the Convention), the Republic of North Macedonia declares that the term ???competent authority??? in relation to the Republic of North Macedonia means the Ministry of Finance or its authorised representative.
    Annex C ??? Definition of the term ???nationals???
    Pursuant to Article 3, paragraph 1.e, of the Convention (for the purposes of Annex C of the Convention), the Republic of North Macedonia declares that the term ???national??? in relation to the Republic of North Macedonia shall be understood as:
    i. any individual possessing the nationality of the Republic of North Macedonia, and
    ii. any legal person, partnership or association and other entity deriving its status as such from the laws in force in the Republic of North Macedonia.

  • PUOLA
    Sitoutumispäivä: 25.06.1997 R
    Voimaantulopäivä: 01.10.1997
    Varauma:

    1. Pursuant to sub-paragraph (a) of paragraph 1 of Article 30 of the Convention, the Republic of Poland will not provide any form of assistance in relation to the taxes of other Parties listed in sub-paragraphs (b)(i) or (b)(iv) of paragraph 1 of Article 2 (taxes imposed by or on behalf of political subdivisions or local authorities);

    In accordance with paragraph 3 of Article 4 of the Convention, the competent authority of the Republic of Poland may inform the persons concerned before transmitting information concerning them to another Party, in conformity with Articles 5 to 7 of the Convention.

    The following text should be included under Annex A in accordance with paragraph 2 of Article 2 of the Convention:

    "For the Republic of Poland, the Convention shall apply to the taxes referred to in sub-paragraphs (a)(i)-(iii) and (b) (ii)-(iii) of paragraph 1 of Article 2".

    The following text should be included under Annex B in accordance with sub-paragraph (d) of paragraph 1 of Article 3 of the Convention:

    "For the Republic of Poland, the term "competent authority" means the Minister of Finance or his authorized representative".

  • QATAR
    Sitoutumispäivä: 17.09.2018 R
    Voimaantulopäivä: -
    Varauma:

    Notifications

    ANNEX A ??? Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i: Income tax
    ANNEX B ??? Competent Authorities:
    The Minister of Finance or his authorised representative.

    Declarations
    According to Article 9, paragraph 3, of the Convention, the State of Qatar does not accept, as a general rule, requests made by applicant States to allow the representatives of their competent authority to be present at the appropriate part of a tax examination in the State of Qatar.
    According to Article 29, paragraph 1, of the Convention, the territory of the State of Qatar, when used in the geographical sense, means the State of Qatar???s lands, internal waters and territorial sea including its bed and subsoil, the air space over them, and the exclusive economic zone and the continental shelf over which the State of Qatar exercises sovereign rights and jurisdiction in accordance with the provisions of international law and the State of Qatar???s national laws and regulations.

    Reservations
    According to Article 30, paragraph 1.a, of the Convention, the State of Qatar reserves the right not to provide any form of assistance in relation to taxes of other Parties in any of the categories listed in Article 2, paragraph 1.b.
    According to Article 30, paragraph 1.b, of the Convention, the State of Qatar reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    According to Article 30, paragraph 1.d, of the Convention, the State of Qatar reserves the right not to provide assistance in the service of documents for all taxes.

  • RANSKA
    Sitoutumispäivä: 25.05.2005
    Voimaantulopäivä: 01.09.2005
    Varauma:

    Article 2

    ANNEX A - Tax covered

    Article 2, paragraph 1.a.:
    i) Income tax;
    . General social contribution;
    . Social debt repayment contribution;
    . Corporation tax;
    . Withholding tax on income from movable assets;
    . Annual flat-rate tax on companies;
    . Corporation tax contribution;
    . Payroll taxes and contributions;

    ii) Not applicable;

    iii) Solidarity wealth tax;
    . Tax on the market value of immovables held in France by legal persons;

    Article 2, paragraph 1.b.:
    i) Not applicable;

    ii) Not applicable;

    iii) A. - Duties on the free transfer of assets;
    B. - Not applicable;
    C. - Value-added tax and similar taxes;
    D. - Indirect contributions;
    E. - Taxes on company cars;
    F. - Various taxes provided for under the General Tax Code and paid to the Government;
    G. - Stamp duties, registration fees and cadastral taxes paid to the Government, stock exchange transaction tax, tax on the income from accumulation or capital bonds, tax on sums paid by insurance and similar bodies and tax on insurance contracts;
    iv) Built-up properties tax and land tax;
    . Occupancy tax;
    . Business tax;
    . Land motor-vehicle excise duty;
    . Stamp duty on registration certificates for land motor-vehicles;
    . Stamp duty and cadastral tax on transfers for consideration of immovable property not intended for use as dwellings;
    . Surcharge on registration fees and cadastral taxes payable on transfers of immovable property;
    . Departemental mining concession taxes;
    . Local infrastructure tax;
    . Special infrastructure tax of the Ile-de-France region and its supplementary tax;
    . Tax on driving licences;
    . Communal tax assimilated to direct local taxes;
    . Indirect taxes for local communities and various bodies.

    Article 29

    France confirms that its approval of the Convention was subject by the following reservation :
    In accordance with Article 29, paragraph 1, France intends to reserve the application of this Convention to the European and Overseas D?partements of the French Republic, including the territorial sea and, beyond it, the areas over which, in accordance with international law, the French Republic has sovereign rights for the purpose of exploring and exploiting the natural resources of the seabed and its subsoil and superjacent waters.

    Article 3

    ANNEX B - Competent authorities

    France declares that the competent authorities withing the meaning of Article 3, paragraph 1.d, of the Convention are :

    1. For the contributions referred to in Chapter VI of Title III of Book I of the Social Security Code and in Chapter II of Ordinance No. 96-50 of 24 January 1996 on the social debt repayment:

    - concerning those recovered by social security bodies : as appropriate, the Chairman of the Administrative Council of the Central Agency for Social Security Bodies (Agence centrale des organismes de s?curit? sociale - ACOSS) or the Chairman of the Administrative Council of the Agricultural Social Insurance Mutual Benefit Fund (Caisse centrale de mutualit? sociale agricole - CCMSA);
    - concerning those recovered by the Treasury: the Minister responsible for the Budget or his authorised representative;

    2. For all the other taxes referred to in Annex A : the Minister responsible for the Budget or his authorised representative.

  • ROMANIA
    Sitoutumispäivä: 11.07.2014 R
    Voimaantulopäivä: 01.11.2014
  • RUANDA
    Sitoutumispäivä: 11.08.2021 A
    Voimaantulopäivä: -
    Varauma:

    Reservations and declarations contained in a Note verbale from the Ambassador of the Republic of
    Rwanda to France, dated 11 August 2021, handed over to the
    Secretary General of the OECD at the time of signature of the
    instrument, on 11 August 2021

    In accordance with Article 30, paragraph 1.a, of the Convention, Rwanda reserves the right not to provide
    any form of assistance in relation to the taxes of other Parties in any of the following categories mentioned
    of Article 2, paragraph 1.b:
    i.: taxes on income, profits, capital gains or net wealth which are imposed on behalf of political
    subdivisions or local authorities of a Party;
    ii.: compulsory social security contributions payable to general government or to social security
    institutions established under public law;
    iv.: taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political
    subdivisions or local authorities of a Party.
    In accordance with Article 30, paragraph 1.c, of the Convention, Rwanda reserves the right not to provide
    assistance in respect of any tax claim, which is in existence at the date of entry into force of the
    Convention in respect of that State or, where a reservation has previously been made under subparagraph a or b, at the date of withdrawal of such a reservation in relation to taxes in the category in
    question.
    In accordance with Article 30, paragraph 1.d, of the Convention, Rwanda reserves the right not to provide
    assistance in the service of documents for all taxes.
    In accordance with Article 30, paragraph 1.f, of the Convention, Rwanda reserves the right to apply
    Article 28, paragraph 7, exclusively for administrative assistance related to taxable periods beginning on
    or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010
    Protocol, entered into force in respect of Rwanda, or where there is no taxable period, for administrative
    assistance related to charges to tax arising on or after 1 January of the third year preceding the one in
    which the Convention, as amended by the 2010 Protocol, entered into force in respect of Rwanda.
    3 / 4
    Rwanda ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the
    Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters, with the following
    notifications:
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    . personal income tax,
    . corporate income tax,
    . pay as you earn,
    . withholding taxes.
    Article 2, paragraph 1.a.ii: capital gains tax.
    Article 2, paragraph 1.b.iii.C: value added tax.
    Article 2, paragraph 1.b.iii.D: excise duty.
    Article 2, paragraph 1.b.iii.E: tax on transfer of motor vehicles.
    Article 2, paragraph 1.b.iii.G:
    . tax on minerals,
    . gaming tax.
    ANNEX B ??? Competent Authorities
    The Minister responsible for Finance and/or the Commissioner General of the Rwanda Revenue
    Authority.
    ANNEX C ??? Definition of the word "national" for the purpose of the Convention
    (i) all individuals possessing the nationality of Rwanda;
    (ii) all legal persons, partnerships and associations deriving their status as such from the laws in force
    in Rwanda.
    In accordance with Article 29, paragraph 1, of the Convention, Rwanda declares that the Convention
    shall apply to all parts of the territory of the Republic of Rwanda including lakes and any other area in the
    lakes and in the air within which Rwanda may exercise sovereign rights of jurisdiction in accordance with
    international law.

  • RUOTSI
    Sitoutumispäivä: 04.07.1990
    Voimaantulopäivä: 01.04.1995
    Varauma:

    ANNEX A - Taxes to which the Convention would apply

    (Paragraph 2 of Article 2 of the Convention)

    Article 2, paragraph 1.a:

    i. The State income tax (den statliga inkomstskatten)
    the sailors' tax (sj?mansskatten)
    the coupon tax (kupongskatten)
    the tax on public entertainers (bevillningsavgiften f?r s?rskilda f?rm?ner och r?ttigheter)
    the tax on the undistributed profits of companies (ers?ttningsskatten)
    the tax on distribution in connection with reduction of share capital or the winding up of a company (utskiftningsskatten), and
    the profit sharing tax (vinstdelningsskatten).

    iii. The State capital tax (den statliga f?rm?genhetsskatten)

    Article 2, paragraph 1.b:

    i. The communal income tax (den kommunala inkomstskatten)

    ii. Charges according to:
    - the Act (1981:691) on Social Security Contributions [lagen (1981:691) om socialavgifter]
    - the Act (1982:423) on General Payroll Fee [lagen (1982:423) om allm?n l?neavgift]
    - the Act (1984:668) on the Collection of Social Security Contributions from Employers [lagen (1984:668) om uppb?rd av socialavgifter fr?n arbetsgivare], and
    - the Act (1989:484) on Work Environment Fee [lagen (1989:484) om arbetsmilj?avgift].

    iii. A. The inheritance tax and the gift tax (arvsskatten och g?voskatten).

    B. The State tax on real estate (den statliga fastighetsskatten).

    C. Taxes according to the Act (1968:430) on Value Added Tax [lagen (1968:430) om merv?rdeskatt].

    D. Taxes according to the Act (1978:144) on Tax on certain travels [lagen (1978:144) om skatt p? vissa resor], and the Act (1983:1053) on turnover tax on certain securities [lagen (1983:1053) om skatt p? oms?ttning av vissa v?rdepapper].

    E. Charges and taxes according to :

    - the Road Traffic Tax Act (1973:601) [v?gtrafikskattelagen (1973:601)]
    - the Act (1976:338) on Road Traffic Tax on Vehicles which are not registered in Sweden [lagen (1976:388) om v?gtrafikskatt p? vissa fordon som inte ?r registrerade h?r i riket]
    - the Act (1976:339) on Tax on Cars for Sale [lagen (1976:339) om saluvagnsskatt]
    - the Road Traffic Tax Act (1988:327) [v?gtrafiksskattelagen (1988:327)], and
    - the Road Traffic Tax Act (1988:328) on foreign vehicles [lagen (1988:328) om v?gtrafikskatt p? utl?ndska fordon].

    G. Charges according to the Act (1972:435) on Fee on Excess Freight [lagen (1972:435) om ?verlastavgift].

    ANNEX B - Competent authorities

    (paragraph 1.d of Article 3 of the Convention)

    The Minister of Finance or the National Tax Board.

  • SAINT KITTS JA NEVIS
    Sitoutumispäivä: 25.08.2016 R
    Voimaantulopäivä: 01.12.2016
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 25 August 2016

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Federation of Saint Kitts and Nevis shall not provide any form of assistance in relation to the taxes of other Parties as mentioned in Article 2, paragraph 1, sub-paragraphs b.i to b.iv, of the Convention.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Federation of Saint Kitts and Nevis shall not provide assistance in the recovery of tax claims, or in the recovery of administrative fines, for all taxes.
    Pursuant to Article 30, paragraph 1.c, of the Convention, the Federation of Saint Kitts and Nevis shall not provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Saint Kitts and Nevis or, if the tax claim is in relation to taxes that are listed in the reservation made under Article 30, paragraph 1.a or b, of the Convention, at the date of withdrawal of such reservation by Saint Kitts and Nevis.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Federation of Saint Kitts and Nevis shall not provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.e, of the Convention, the Federation of Saint Kitts and Nevis reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.
    Pursuant to Article 30, paragraph 1.f, of the Convention, the Federation of Saint Kitts and Nevis reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Federation of Saint Kitts and Nevis, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention as amended by the 2010 Protocol, entered into force in respect of the Federation of Saint Kitts and Nevis.
    Pursuant to Article 4, paragraph 3, of the Convention, the Federation of Saint Kitts and Nevis may inform its resident or national before transmitting information concerning him to another Party, in conformity with Articles 5 and 7 of the Convention.
    Pursuant to Article 9, paragraph 3, of the Convention, the Federation of Saint Kitts and Nevis shall not accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the Convention.
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    Income tax;
    Article 2, paragraph 1.b.i:
    Income tax;
    ANNEX B - Competent authorities
    The Financial Secretary or the Financial Secretary???s authorised representative.


    Partial withdrawal of a reservation contained in a Note verbale from the Ministry of Foreign Affairs of Saint Christopher and Nevis, dated 29 September 2016, registered at the Secretariat General of the OECD on 26 October 2016

    The Government of St. Kitts and Nevis is desirous of having the reservation made pursuant to Article 30, paragraph 1.a, of the Convention amended to read as follow:
    Pursuant to Article 30, paragraph 1.a, of the Convention, the Federation of Saint Kitts and Nevis shall not provide any form of assistance in relation to the taxes of other Parties as mentioned in Article 2, paragraph 1, sub-paragraphs b.ii to b.iv, of the Convention.
    ______
    Note by the Secretariat: The reservation read as follows: ???Pursuant to Article 30, paragraph 1.a, of the Convention, the Federation of Saint Kitts and Nevis shall not provide any form of assistance in relation to the taxes of other Parties as mentioned in Article 2, paragraph 1, sub-paragraphs b.i to b.iv, of the Convention

  • SAINT LUCIA
    Sitoutumispäivä: 21.11.2016 R
    Voimaantulopäivä: 01.03.2017
  • SAINT VINCENT JA GRENADIINIT
    Sitoutumispäivä: 31.08.2016 R
    Voimaantulopäivä: 01.12.2016
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 31 August 2016

    Pursuant to Article 30, paragraph 1.a, of the Convention, Saint Vincent and the Grenadines reserves the right not to provide any form of assistance in relation to the taxes of other Parties described in any of the categories listed in Article 2, paragraph 1.b, of the Convention.
    Pursuant to Article 30, paragraph 1.b, of the Convention, Saint Vincent and the Grenadines reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1.c, of the Convention, Saint Vincent and the Grenadines reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Saint Vincent and the Grenadines, or, if the tax claim is in relation to taxes which are listed in the reservation made under Article 30, paragraph 1.a or b of the Convention, at the date of withdrawal of such a reservation by Saint Vincent and the Grenadines.
    Pursuant to Article 30, paragraph 1.d, of the Convention, Saint Vincent and the Grenadines will not provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.e, of the Convention, Saint Vincent and the Grenadines reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.
    Pursuant to Article 30, paragraph 1.f, of the Convention, Saint Vincent and the Grenadines reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Saint Vincent and the Grenadines, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Saint Vincent and the Grenadines.
    Pursuant to Article 4, paragraph 3, of the Convention, Saint Vincent and the Grenadines may inform its resident or national before transmitting information to another party, in conformity with Article 5 and Article 7 of the Convention.
    2
    Pursuant to Article 9, paragraph 3, of the Convention, Saint Vincent and the Grenadines will not accept, as a general rule, requests referred to in Article 9, paragraph 1, of the Convention.
    ANNEX A - Taxes to which the Convention would apply.
    Article 2, paragraph 1.a.i: Income Tax
    Article 2, paragraph 1.a.ii: Corporate Tax
    ANNEX B - Competent authorities
    The Inland Revenue Department or an authorised representative which may be designated by the Minister with responsibility for Finance.
    ANNEX C - Definition of the word "national" for the purpose of the Convention
    The term ???nationals??? means any individual possessing the nationality or citizenship of Saint Vincent and the Grenadines and any legal person, partnership, association or other organisation deriving their status as such from the laws in force in Saint Vincent and the Grenadines.

  • SAMOA
    Sitoutumispäivä: 31.08.2016 R
    Voimaantulopäivä: 01.12.2016
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 31 August 2016

    Pursuant to paragraph 1.a of Article 30 of the Convention, the Independent State of Samoa reserves the right not to provide any form of assistance in relation to the taxes of other Parties listed in sub-paragraphs b.i, b.ii, b.iii B, C, D, E, F, G and b.iv of paragraph 1 of Article 2.
    Pursuant to paragraph 1.b of Article 30 of the Convention, the Independent State of Samoa reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes listed in paragraph 1 of Article 2.
    Pursuant to paragraph 1.c of Article 30 of the Convention, the Independent State of Samoa reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of that State.
    Pursuant to paragraph 1.f of Article 30 of the Convention, the Independent State of Samoa reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i: Taxes on income or profits
    Article 2, paragraph 1.a.ii: Taxes on capital gains
    Article 2, paragraph 1.a.iii: Taxes on net wealth
    Article 2, paragraph 1.b. iii A: Estate, inheritance or gift tax
    ANNEX B - Competent authorities
    The Minister for Revenue or his authorised representative.

  • SAUDI-ARABIA
    Sitoutumispäivä: 01.06.2011
    Voimaantulopäivä: 01.04.2016
    Varauma:

    Reservations and Declaration

    SAUDI ARABIA
    Amendment of a declaration transmitted by the Embassy of Saudi Arabia to France and registered at the Secretariat General of the OECD on 6 January 2020
    Annex A - Taxes to which the Convention would apply:
    Article 2, paragraph 1.a.i:
    - The income tax including the natural gas investment tax
    - The Zakat, and
    Article 2, paragraph 1.b.iii.C:
    - Value Added tax,
    Article 2, paragraph 1.b.iii.D:
    - Excise Tax.

  • SENEGAL
    Sitoutumispäivä: 25.08.2016 R
    Voimaantulopäivä: 01.12.2016
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 25 August 2016

    In accordance with Article 30, paragraph 1.a, of the Convention, the Republic of Senegal reserves the right not to provide any form of assistance in relation to the taxes of other Parties in any of the categories listed in Article 2, paragraph 1, sub-paragraph b:
    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;
    ii. compulsory social security contributions payable to general government or to social security institutions established under public law, and
    iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:
    A. estate, inheritance or gift taxes,
    B. taxes on immovable property,
    C. general consumption taxes, such as value-added or sales taxes,
    F. taxes on the use or ownership of movable property other than motor vehicles, and
    iv. taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.
    In accordance with Article 30, paragraph 1.b, of the Convention, the Republic of Senegal reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    In accordance with Article 30, paragraph 1.d, of the Convention, the Republic of Senegal reserves the right not to provide assistance in the service of documents for all taxes.
    In accordance with Article 30, paragraph 1.f, of the Convention, the Republic of Senegal reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of Senegal, or, where
    2
    there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of Senegal.
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    ??? Corporation tax ;
    ??? Minimum flat rate Corporation tax;
    ??? Tax on income of individuals;
    Article 2, paragraph 1.a.ii:
    ??? Taxes on capital gains which are imposed separately from the tax on income or profits;
    Article 2, paragraph 1.b.iii.D:
    ??? Value-added tax;
    ??? Tax on financial activities;
    Article 2, paragraph 1.b.iii.E :
    ??? Excise taxes ;
    Article 2, paragraph 1.b.iii.G :
    ??? Flat rate contribution borne by employers.
    ANNEX B - Competent authorities
    The Minister of Economy, Finance and Planning or the Director General of Taxes and Domains.
    ANNEX C - Definition of the word "national" for the purpose of the Convention
    All individuals of Senegalese nationality and all legal persons, partnerships or capital companies, associations and other entities provided for and constituted in accordance with the laws in force in Senegal.

  • SERBIA
    Sitoutumispäivä: 30.08.2019 R
    Voimaantulopäivä: 01.12.2019
    Varauma:

    Reservations and Declarations contained in the instrument of ratification deposited with the Secretariat General of the OECD on 30 August 2019

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Serbia reserves the right not to provide any form of assistance in relation to the taxes of other Parties to the Convention in any of the categories listed in Article 2, paragraph 1.b, of the Convention, provided that domestic taxes in that category are not included in Annex A of the Republic of Serbia.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Serbia reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine for taxes listed in any of the categories listed in paragraph 1 of

    Article 2.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Serbia reserves the right not to provide assistance in the service of documents for taxes listed in any of the categories listed in paragraph 1 of Article 2.
    Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of Serbia reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.
    The Republic of Serbia declares that, according to its internal legislation, its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7.
    The Republic of Serbia informs of its intention not to accept, as a general rule, such requests as are referred to in paragraph 1 of Article 9 of the Convention.
    Annex A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    ??? Personal Income tax
    ??? Corporate Income tax
    Annex B - Competent authorities
    The Ministry of Finance or its authorised representative.

  • SEYCHELLIT
    Sitoutumispäivä: 25.06.2015 R
    Voimaantulopäivä: 01.10.2015
    Varauma:

    Pursuant to Article 30, paragraph 1.a, of the Convention, Seychelles reserves the right not to provide any form of assistance in relation to the taxes of other Parties described in sub-paragraph b. of paragraph 1 of Article 2.

    Pursuant to Article 30, paragraph 1.b, of the Convention, Seychelles reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

    Pursuant to Article 30, paragraph1.c, of the Convention, Seychelles reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Seychelles or, where a reservation has previously been made under sub-paragraph a or b of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

    Pursuant to Article 30, paragraph1.d, of the Convention, Seychelles reserves the right not to provide assistance in the service of documents for all taxes.

    Pursuant to Article 30, paragraph1.f, of the Convention, Seychelles reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

    ANNEX A ??? Taxes to which the Convention would apply

    Article 2, paragraph 1.a.i

    Business tax;
    Income and non-monetary benefits tax;
    Petroleum income tax;

    ANNEX B ??? Competent Authorities

    The Minister of Finance or an authorised representative of the Minister of Finance.

    ANNEX C ??? Definition of the word "national" for the purpose of the Convention

    (i) any individuals possessing the nationality or citizenship of Seychelles
    (ii) any legal person, partnership or association deriving its status as such from the laws in force in Seychelles.

    Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

    Considering that Seychelles has committed to automatically exchange information in of 2017 and that, in order to be able to automatically exchange information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters (hereafter the ???amended Convention???) Seychelles has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the ???CRS MCAA???) on 14 May 2015;
    Considering that, pursuant to its Article 28(6), the amended Convention shall have effect for administrative assistance related to taxable periods beginning on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the amended Convention entered into force in respect of a Party;

    Considering that Article 28(6) of the amended Convention provides that any two or more Parties may mutually agree that the amended Convention shall have effect for administrative assistance related to earlier taxable periods or charges to tax;
    Mindful that information may only be sent by a jurisdiction under the amended Convention with respect to taxable periods or charges to tax of the receiving jurisdiction for which the amended

    Convention is in effect and that, as a consequence, sending jurisdictions for which the Convention has newly entered into force in a given year are only in a position to provide administrative assistance to receiving jurisdictions for taxable periods beginning or charges to tax arising on or after 1 January of the following year;

    Acknowledging that an existing Party to the amended Convention would be able to receive information under Article 6 of the amended Convention and the CRS MCAA from a new Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention if both Parties declare to agree that another date of effect is applicable;

    Further acknowledging that, therefore, a new Party to the amended Convention would be able to send information under Article 6 of the amended Convention and the CRS MCAA to an existing Party with respect to earlier taxable periods or charges to tax than the date foreseen in the amended Convention, if both Parties declare to agree that another date of effect is applicable;

    Recognising that the information received under Article 6 of the amended Convention and the CRS MCAA may lead to follow-up requests by the receiving jurisdiction to the sending jurisdiction, which would relate to the same reporting period for which the sending jurisdiction has automatically exchanged information under the CRS MCAA;

    Confirming that the capacity of a jurisdiction to send CRS-related information under Article 6 of the amended Convention and the CRS MCAA, as well as information relating to follow-up requests pursuant to Article 5 of the amended Convention, shall be governed by the terms of the CRS MCAA, including the relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods or charges to tax of the receiving jurisdiction to which such information relates;
    Seychelles declares that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between Seychelles and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction.

    Seychelles declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between Seychelles and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, when such assistance concerns follow-up requests related to information exchanged under the CRS MCAA with respect to reporting periods of the sending jurisdiction covered by the CRS MCAA

  • SINGAPORE
    Sitoutumispäivä: 20.01.2016 R
    Voimaantulopäivä: 01.05.2016
    Varauma:

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Singapore reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the categories listed in Article 2, paragraph 1.b.

    Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Singapore reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

    Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of Singapore reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Singapore or, where a reservation has previously been made under sub-paragraph a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Singapore reserves the right not to provide assistance in the service of documents for all taxes.

    Pursuant to Article 30, paragraph 1.e, of the Convention, the Republic of Singapore reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.

    Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of Singapore reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of Singapore, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of Singapore.

    In accordance with Article 4, paragraph 3, of the Convention, the Republic of Singapore declares that its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7 of the Convention.

    ''''''''''''''''''''''''

    Declaration and partial withdrawal of a reservation contained in a Notification from the Minister for Foreign Affairs of Singapore, dated 10 October 2019, registered at the Secretariat General of the OECD on 28 October 2019

    The Government of the Republic of Singapore, having reviewed the notification on the taxes to which the Convention applies in the case of the Republic of Singapore (Annex A), modifies it as follows:
    ANNEX A - Taxes to which the Convention would apply
    For the purposes of Article 2, paragraph 2, the following taxes apply in the case of the Republic of Singapore:
    Article 2, paragraph 1.a.i: Income Tax, and
    Article 2, paragraph 1.b.iii.C: Goods and Services Tax.
    The Government of the Republic of Singapore, having reviewed the reservation made under Article 30, paragraph 1.a, of the Convention, modifies it as follows:
    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Singapore reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the categories listed in Article 2, paragraph 1.b., except in relation to Goods and Services Tax under Article 2, paragraph 1.b.iii.C.

    Note by the Secretariat:
    In compliance with the provisions of the Convention and as requested by Singapore, such changes shall take effect for Singapore on 1 February 2020.

  • SLOVENIA
    Sitoutumispäivä: 31.01.2011 R
    Voimaantulopäivä: 01.05.2011
    Varauma:

    Article 30

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Slovenia reserves the right not to provide any form of assistance in relation to taxes of other Parties included in one of the following categories listed in Article 2, paragraph 1.b :

    ii.: compulsory social security contributions payable to general government or to social security institutions established under public law,

    iii.B : taxes on immovable property;
    iii.E : taxes on the use or ownership of motor vehicles;
    iii.F : taxes on the use or ownership of movable property other than motor vehicles;

    iv.: taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

    Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Slovenia reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for taxes listed in the reservation made under Article 30, paragraph 1.a.

    Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of Slovenia reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Slovenia or, if the tax claim is in relation to taxes, which are included in the reservation made under Article 30, paragraphs 1.a or 1.b, at the date of withdrawal of such a reservation by the Republic of Slovenia.

    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Slovenia reserves the right not to provide assistance in the service of documents for taxes listed in the reservation made under Article 30, paragraph 1.a.

    Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of Slovenia reserves the right to apply Article 28, paragraph 7, exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force for the Republic of Slovenia.

    Article 2

    For the Republic of Slovenia, the Convention shall apply to thoses taxes in Article 2, paragraph 1, which fall within :

    Article 2, paragraph 1.a.i.:
    . taxes on income of individuals (davek od dohodkov fizicnih oseb - dohodnina);
    . taxes on income of legal persons (davek od dohodkov pravnih oseb).

    Article 2, paragraph 1.b.iii.:
    A: inheritance and gift ta (davek na dediscine in darila);
    C: value-added tax (davek na dodano vrednost);
    D: excise duties (trosarine);
    G: real estate transaction tax (davek od prometa nepremicnin).

    Article 3

    Pursuant to Article 3 of the Convention, in relation to the Republic of Slovenia, the term "competent authority" means the Ministry of Finance of the Republic of Slovenia or its authorised representative.

  • SUOMI
    Sitoutumispäivä: -
    Voimaantulopäivä: -
    Varauma:

    ANNEX A - Taxes to which the convention would apply

    Article 2, paragraph 1 (a)

    (i)

    the state income taxes (valtion tuloverot); de statliga inkomstskatterna),
    the corporate income tax (yhteis?jen tulovero; inkomstskatten f?r samfund),
    the tax withheld at source from non-residents' income (rajoitetusti verovelvollisen l?hdevero; k?llskatten f?r begr?nsat skattskyldig),
    the tax withheld at source from interest (korkotulon l?hdevero; k?llskatten p? r?nteinkomst),
    the withholding tax for foreign employees (ulkomailta tulevan palkansaajan l?hdevero; k?llskatt f?r l?ntagare fr?n utlandet),

    (ii)

    -

    (iii)

    the state capital tax (valtion varallisuusvero; den statliga f?rm?genhetsskatten),

    Article 2, paragraph 1 (b):

    (i)

    the communal tax (kunnallisvero; kommunalskatten),
    the church tax (kirkollisvero; kyrkoskatten),
    the forestry duty (mets?nhoitomaksu; skogsv?rdsavgiften),

    (ii)

    the national pension insurance contribution (vakuutetun kansanel?kevakuutusmaksu; f?rs?krads folkpensionsf?rs?kringspremie),
    the health insurance contribution (vakuutetun sairausvakuutusmaksu; f?rs?krads sjukf?rs?kringspremie),
    the employer's social security contribution (ty?nantajan sosiaaliturvamaksu; arbetsgivares socialskyddsavgift),

    (iii) A

    the inheritance tax and the gift tax (perint?vero ja lahjavero; arvsskatten och g?voskatten),

    (iii) B

    -

    (iii) C

    the value added tax (arvonlis?vero; merv?rdesskatten),

    (iii) D

    the excise duty on tobacco (tupakkavero; tobaksaccisen),
    the excise duty on soft drinks (virvoitusjuomavero; l?skedrycksaccisen),
    the excise duty on liquid fuels (nestem?isten polttoaineiden valmistevero; accisen p? flytande br?nslen),
    the excise duty on electricity and certain energy sources (s?hk?n ja er?iden polttoaineiden valmistevero; accis p? elstr?m och vissa br?nslen),
    the excise duty on alcohol and alcoholic beverages (alkoholi- ja alkoholijuomavero; accisen p? alkohol och alkoholdrycker),
    the tax on certain insurance premiums (er?ist? vakuutusmaksuista suoritettava vero; skatten p? vissa f?rs?kringspremier),
    the oil waste duty (?ljyj?temaksu; oljeavfallsavgiften),
    the motor-car tax (autovero; bilskatten)

    (iii) E

    the tax on specific motor vehicles (moottoriajoneuvovero; motorfordonsskatten),
    the fuel fee (polttoainemaksu; br?nsleavgift),
    the vehicle tax (ajoneuvovero; fordonsskatt),

    (iii) F

    -

    (iii) G

    the stamp duty (leimavero; st?mpelskatten),
    the oil damage duty (?ljysuojamaksu, oljeskyddsavgiften),
    the transfer tax (varallisuudensiirtovero; ?verl?telseskatt),
    the tax on lottery prizes (arpajaisvero; lotteriskatt),
    the tax on waste (j?tevero; avfallsskatt),

    (iv)

    the municipal tax on real property (kiinteist?vero; fastighetsskatten)

    ANNEX B - Competent authorities

    Article 3, paragraph 2 (d):

    The National Board of Taxes.

  • SVEITSI
    Sitoutumispäivä: 26.09.2016 R
    Voimaantulopäivä: 01.01.2017
    Varauma:

    Reservations and declarations contained in the instrument of ratification and in a Note Verbale from the Permanent Delegation of Switzerland to the OECD, deposited with the Secretary General of the OECD on 26 September 2016
    Reservations
    1. In accordance with Article 30, paragraph 1.a, of the Convention, Switzerland does not provide any form of administrative assistance in relation to the taxes referred to in Article 2, paragraphs 1.b.ii to iv, of the Convention.
    2. In accordance with Article 30, paragraph 1.b, of the Convention, Switzerland does not provide administrative assistance in the recovery under Articles 11 to 16 of the Convention for the taxes listed in Article 2, paragraph 1, of the Convention.
    3. In accordance with Article 30, paragraph 1.c, of the Convention, Switzerland does not provide assistance in respect of tax claims which are in existence at the date of entry into force of the Convention in respect of Switzerland; in case of withdrawal of a reservation as defined in numbers 1 and 2, Switzerland does not provide any administrative assistance in respect to tax claims existing at the date of withdrawal of such a reservation in relation to taxes of the mentioned category.
    4. In accordance with Article 30, paragraph 1.d, of the Convention, Switzerland does not provide any administrative assistance in the service of documents under Article 17, paragraph 1, of the Convention, for the taxes listed in Article 2, paragraph 1, of the Convention.
    5. In accordance with Article 30, paragraph 1.f, of the Convention, Switzerland applies Article 28, paragraph 7, of the Convention exclusively:
    a. if a taxable period exists, for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention entered into force in respect of a Party;
    b. where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention entered into force in respect of a Party.

    Declarations
    1. In accordance with Article 4, paragraph 3, of the Convention, the competent Swiss authority may inform the persons concerned before providing information concerning them in conformity with Articles 5 and 7 of the Convention.
    2. In accordance with Article 9, paragraph 3, of the Convention, Switzerland does not accept requests aiming to allow representatives of the competent authority of the applicant State to be present at tax examinations in Switzerland.
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i
    - Federal taxes on income (overall income, earned income from work, income from capital, industrial and commercial profits, capital gains and other income);
    Article 2, paragraph 2.b.i
    - Cantonal and communal taxes on income (overall income, earned income from work, income from capital, industrial and commercial profits, capital gains and other income);
    - Cantonal and communal taxes on wealth (total property, movable and immovable property, business assets, capital and reserves, and other elements of wealth).
    ANNEX B - Competent authorities
    The Swiss competent authority to be mentioned in Annex B of the Convention is the ???Head of the Federal Department of Finance or his authorised representative???.

  • SWAZIMAA
    Sitoutumispäivä: 16.03.2021 R
    Voimaantulopäivä: 01.07.2021
    Varauma:

    Declarations contained in the instrument of ratification deposited with the Secretary General of the
    OECD on 16 March 2021 - Or. Engl.
    Eswatini ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the
    Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters, with the following
    notifications:
    ANNEX A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i: Income Tax.
    Article 2, paragraph 1.b.ii: Statutory Provident Fund and Public Pension Fund.
    Article 2, paragraph 1.b.iii.B:
    . Property Rates/Municipal Rates;
    . Transfer Duty;
    . Stamp Duty.
    Article 2, paragraph 1.b.iii.C: Value Added Tax.
    Article 2, paragraph 1.b.iii.D: Excise Duties.
    Article 2, paragraph 1.b.iii.E: Motor Vehicle Licence Fees.
    Article 2, paragraph 1.b.iii.F: TV licences.
    Article 2, paragraph 1.b.iii.G:
    . Alcohol and Tobacco Levy;
    . Company Licences;
    . Lottery Levy;
    . Liquor Licences;
    . Trading Licences;
    . Fuel Levy;
    . Graded Tax;
    . Cattle Export and Slaughter Tax.
    ANNEX B ??? Competent Authorities
    The Minister of Finance or his Authorised Representative.

  • TANSKA
    Sitoutumispäivä: 16.07.1992 H
    Voimaantulopäivä: 01.04.1995
    Varauma:

    As regards Denmark, the Convention shall apply to the territory of the Kingdom of Denmark including the territorial sea of Denmark as well as any other maritime area to the extent that that area, in accordance with international law, has been or may hereafter be designated under Danish laws as an area within which Denmark may exercise sovereign rights for the purpose of exploring and exploituing the natureal resources of the seabed or its sub-soil and the superjacent waters and with regard to other activities for the exonomic exploration and exploitation of the area; for the purpose of this Convention the term also includes the autonomous regions within the Kingdom of Denmark of Greenland and the Faroe Islands.

    ANNEX B

    DENMARK (except for Greenland)

    The Minister for Taxation of his authorised representative,

    GREENLAND

    The Local Government or its authorised representative.

    The Convention will continue to apply to taxes that have been repealed or renamed as long as the taxes remain enforceable and collectible.

    ANNEX A (Tax covered)

    Danish taxes :

    Article 2, paragraph 1.a:
    i.: income taxes to the State (indkomstskatter til staten)

    ii.: --

    iii.: capital tax to the State (formueskat til staten) - repealed as of 1 January 1997, enforceable and collectible until 1 January 2002 (in cases of fraud until 1 January 2017)

    Article 2, paragraph 1.b:
    i.: income tax to the municipalities (kommunal indkomstskat),
    income tax to the county municipalities (amtskommunal indkomstskat),
    tax on immovable property (ejendomsskat);
    tax on assessed value of immovable property (ejendomsv?rdiskat),
    church tax (kirkeskat)

    ii.: labour market contribution (arbejdsmarkedsbidrag),
    special pension contribution (s?rligt pensionsbidrag)

    iii. A : tax on inheritance and gifts (afgift af d?dsboer og gaver)
    iii. B : --

    iii. C: value added tax (merv?rdiafgift),

    iii. D : excise duties imposed by the State (forbrugsafgifter, som p?l?gges af staten)
    iii. E : registration tax on motor vehicles (registreringsafgift af motork?ret?jer),
    weight tax on motor vehicles and other taxes on the ownership or use of motor vehicles (v?gtafgift af motork?ret?jer og andre afgifter p? oje eller brug af motork?ret?jer)

    iii. F : tax on insurances for yachts (afgift af lystfart?sforsikringer)

    iii. G : payroll tax (l?msumsafgift),
    taxes on betting, on casinos and on lottery prizes ( afgift af totalisatorspil, spillekasinoer og gevinster ved lotterispil),
    tax on registration of rights in real property etc. (afgift af tinglysning og registrering af cjer- og pantrettigheder),
    stamp duty (stempelafgift)

    iv. : service charge on business property (d?kningsafgift af forretningsejendom),
    property release tax (frig?relsesafgift)

    Greenlandic taxes :

    Article 2, paragraph 1.a.

    i. : income tax to the Greelandic home rule Government (landsskat, s?rlig landsskat),
    dividend tax (udbytteskat),
    company tax (selskabsskat)

    Article 2, paragraph 1.b.

    i. : municipal tax (kommuneskat),
    common municipal tax (f?lleskommunal skat),
    dividend tax (udbytteskat);
    company tax (selskabsskat)

    ii. : employer's contributions to vocational training (arbejdsgivernes erhvervsuddannelsesbidrag)

    iii. A : tax on inheritance and gifts (afgift af arv og gave)

    iii. C : import duty (indf?rselsafgift)

    iii. D : tax on gambling machines (afgift af automatspil),
    harbour duty (havneafgift),
    tax on sea transport of goods to, from and within Greenland (afgift p? s?transport af gods til, fra og I Gr?nland),
    tax on shrimps (afgift p? rejer)

    iii. E : tax on motor vehicles (afgift af motork?ret?jer)

    iii. G : tax on lottery (lotteriafgift),
    stamp duty (stempelafgift).

    Annex B - Competent Authority
    FAROE ISLANDS
    The Faroe Islands Customs and Tax Administration (Toll- og Skattstova F?roya).

    Annex A (Tax covered)
    Faroese taxes

    Article 2, paragraph 1.a:
    i.: income taxes to the Faroese home rule Government (landsskattur)
    royalty taxes (skattur av n?tslugjaldi)
    taxes levied under the Hydrocarbon Tax Act (skattur eftier kolvetnisskattal?gini)
    taxes levied under the Tonnage Tax Act (skattur eftir tonnsaskattal?gini)

    ii.: taxes levied under the Act on Taxation of Capital Gains (kapitalvinningsskattur)

    Article 2, paragraph 1.b:
    i.: income taxes to the municipalities (komunuskattur)
    church tax (kirkjuskattur)

    ii.: labour market contribution (ALS-gjald)
    special pension contribution (arbeidsmarknareftirl?nargjald)

    iii. C: value added tax (meirvirdisgjald)

    iii. D: import and excise duties (tollur)

    iii. E: registration tax on motor vehicles (skr?setingargjald)
    weight tax on motor vehicles and other taxes on the ownership or use of motor vehicles (veggjald)

    iii. G: Tax on registration of rights in real property (tingl?singargjald)

  • THAIMAA
    Sitoutumispäivä: 22.12.2021 R
    Voimaantulopäivä: 01.04.2022
    Varauma:

    THAILAND
    Declaration accompanying the Full powers handed over at the time of signature of the
    instrument with the Secretariat General of the OECD, on 3 June 2020

    Thailand signs the Convention with the following notification
    ANNEX B ??? Competent Authorities: The Minister of Finance or his authorised representative

    Reservations and declarations contained in the instrument of ratification deposited with the
    Secretary General of the OECD on 22 December 2021

    Pursuant to paragraph 1.a. of Article 30 of the Convention, Thailand reserves the right not to provide any
    form of assistance in relation to the taxes of other Parties included in any of the following categories listed
    in sub-paragraph b. of paragraph 1 of Article 2:
    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political
    subdivisions or local authorities of a Party,
    ii. compulsory social security contributions payable to general government or to social security
    institutions established under public law, and
    iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:
    A. estate, inheritance or gift taxes,
    B. taxes on immovable property,
    C. general consumption taxes, such as value added or sales taxes,
    D. specific taxes on goods and services such as excise taxes,
    E. taxes on the use or ownership of motor vehicles,
    F. taxes on the use or ownership of movables property other than motor vehicles,
    G. any other taxes;
    iv. taxes in categories referred to in sub-paragraph iii. above which are imposed on behalf of
    political subdivisions or local authorities of a Party.
    Pursuant to paragraph 1 b. of Article 30 of the Convention, Thailand reserves the right not to provide
    assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes listed
    in paragraph 1 of Article 2 of the Convention.
    Pursuant to paragraph 1 d. of Article 30 of the Convention, Thailand reserves the right not to provide
    assistance in the service of documents for all taxes listed in paragraph 1 of Article 2 of the Convention.
    Pursuant to paragraph 1 f. of Article 30 of the Convention, Thailand reserves the right to apply
    paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning
    on or after 1 January of the third year preceding the one in which the Convention, as amended by the
    2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for
    administrative assistance related to charges to tax arising on or after I January of the third year preceding
    the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a
    Party.

  • TOGO
    Sitoutumispäivä: 30.01.2020 A
    Voimaantulopäivä: -
  • TSHEKKI
    Sitoutumispäivä: 01.02.2014
    Voimaantulopäivä: -
    Varauma:

    CZECH REPUBLIC
    Declaration contained in a Note verbale from the Permanent Representation of the Czech Republic
    to the Council of Europe, dated 6 October 2020, registered at the Secretariat General on
    9 October 2020

    In accordance with Article 2, paragraph 3, of the Convention on Mutual Administrative Assistance in Tax
    Matters, as amended by the 2010 Protocol (hereinafter ???the Convention???), the Czech Republic notifies the
    new wording of the part of the Annex A that concerns taxes to which the Convention shall apply under its
    Article 2, paragraph 1.a.i. The new wording of the above-mentioned part of the Annex A is:
    Annex A - Taxes to which the Convention would apply:
    Article 2, paragraph 1.b.iii.D:
    - Excise duty on mineral oils, on ethyl alcohol, on beer, on wine and intermediate products and on tobacco
    products, tax on heated tobacco products, tax on raw tobacco, tax on natural gas and some other
    gases, tax on solid fuels, tax on electricity

  • TURKKI
    Sitoutumispäivä: 26.03.2018 R
    Voimaantulopäivä: 01.07.2018
    Varauma:

    Reservations

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Turkey reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b :

    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party,
    ii. compulsory social security contributions payable to general government or to social security
    institutions established under public law, and
    iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

    A. estate, inheritance or gift taxes,
    B. taxes on immovable property,
    D. specific taxes on goods and services such as excise taxes,
    E. taxes on the use or ownership of motor vehicles,
    F. taxes on the use or ownership of movable property other than motor vehicles,
    G. any other taxes,

    iv. taxes in categories referred to in sub-paragraph iii. above which are imposed on behalf of political subdivisions or local authorities of a Party.

    Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of Turkey reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Turkey or, if the tax claim is in relation to taxes, which are included in the reservation made under Article 30, paragraph 1.a, at the date of withdrawal of such a reservation by the Republic of Turkey.

  • UGANDA
    Sitoutumispäivä: 26.05.2016 R
    Voimaantulopäivä: 01.09.2016
    Varauma:

    Reservations and declarations:

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Uganda will not provide any form of assistance inrelation to the taxes of other Parties included in the following categories of Article 2, paragraph 1: Article 2,
    paragraph 1.b.i: taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;
    Article 2, paragraph 1.b.ii: compulsory social security contributions payable to general government or to social security institutions established under public law;
    Article 2, paragraph 1.b.iii.E: taxes on the use or ownership of motor vehicles;
    Article 2, paragraph 1.b.iv: taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Uganda will not provide assistance with regard to the service of documents.

    Annex A - Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    Income Tax, Withholding tax on royalties, Tax on foreign entertainers and sports persons, turnover tax on Small and Medium Enterprises, Gaming and sports betting taxes, Withholding taxes on dividends, Withholding tax on interest

    Article 2, paragraph 1.a.ii:
    Capital
    Article 2, paragraph 1.b.iii.B:
    Stamp duty, Taxes in immovable property including Rental Tax.
    Article 2, paragraph 1.b.iii.C:
    Value Added Tax
    Article2, paragraph 1.b.iii.D:
    Excise Tax.

    Annex B
    The Commissioner General of the Unganda Revenue Authority or an authorized representative of the Commissioner General.
    Annex C
    Definition of the term "national" for the purpose of the Convention
    Any individual possessing the nationality or citizenship of Uganda and any legal person, partnesship or other entity deriving its status as such from the laws in force in Uganda.

  • UKRAINA
    Sitoutumispäivä: 26.03.2009 R
    Voimaantulopäivä: 01.07.2009
    Varauma:

    Ukraina

    Artikla 2

    ANNEX A - Taxes to which the Convention would apply:

    a) sub-paragraph a.i:
    tax on profits of enterprises;
    tax on income of naturals;

    b) sub-paragraph b.i.i:
    compulsory social security contribution;

    c) sub-paragraph b.i.i.i.B:
    land fee;

    d) sub-paragraph b.i.i.i.C:
    value-added tax;

    e) sub-paragraph b.i.i.i.D:
    excise tax;
    duty on the development of viticulture, gardening and hop-growing;

    f) sub-paragraph b.i.i.i.E:
    tax on the ownership of moto vehicles and other self-propelled machines and mechanisms;

    g) sub-paragraph b.iv:
    single tax;
    fixed agricultural tax;
    state customs;
    rental payment;
    duty for the special use of natural resources.

    Article 30

    Ukraine, pursuant to Article 30, paragraph 1.a, of the Convention, reserves the right not to provide the assistance concerning taxes of other Parties not belonging to the list of taxes and dues included by Ukraine into Annex A of the Convention.

    Article 3

    Ukraine, pursuant to Article 30, paragraph 1.c, of the Convention, reserves the right not to provide the assistance concerning any tax debts existing on the date of entry into force of the Convention for Ukraine.

    Article 3

    ANNEX B - Competent authorities

    The State Tax Administration of Ukraine;
    The State Customs Service of Ukraine;
    The Pension Fund of Ukraine.

  • URUGUAY
    Sitoutumispäivä: 31.08.2016 R
    Voimaantulopäivä: 01.12.2016
    Varauma:

    Reservations and declarations contained in the instrument of ratification deposited with the Secretary General of the OECD on 31 August 2016

    Pursuant to Article 30, paragraph 1.a, of the Convention, the Oriental Republic of Uruguay reserves the right not to provide any form of assistance in relation to taxes of other Parties included in one of the following categories listed in Article 2, paragraph 1.b:
    i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political divisions or local authorities of a Party;
    ii. compulsory social security contributions payable to general government or to social security institutions established under public law;
    iii. A. taxes on estate, inheritance or gift tax
    iii. B. taxes on immovable property;
    iii. E. taxes on the use or ownership of motor vehicles;
    iii. F. taxes on the use or ownership of movable property other than motor vehicles;
    iii. G. any other taxes;
    iv. taxes in categories referred to in sub-paragraph iii which are imposed on behalf of political subdivisions or local authorities of a Party.
    Pursuant to Article 30, paragraph 1.b, of the Convention, the Oriental Republic of Uruguay reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
    Pursuant to Article 30, paragraph 1.c, of the Convention, the Oriental Republic of Uruguay reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made under sub-paragraph a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.
    2
    Pursuant to Article 30, paragraph 1.d, of the Convention, the Oriental Republic of Uruguay reserves the right not to provide assistance in the service of documents for all taxes.
    Pursuant to Article 30, paragraph 1.e, of the Convention, the Oriental Republic of Uruguay reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.
    Pursuant to Article 30, paragraph 1.f, of the Convention, the Oriental Republic of Uruguay reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Oriental Republic of Uruguay, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a the Oriental Republic of Uruguay.
    ANNEX A ??? Taxes to which the Convention would apply
    Article 2, paragraph 1.a.i:
    . Tax on business income (Impuesto a las Rentas de las Actividades Econ??micas - IRAE);
    . Personal income tax (Impuesto a las Rentas de las Personas F??sicas - IRPF);
    . Non-residents income tax (Impuesto a las Rentas de los No Residentes - IRNR);
    . Tax for social security assistance (Impuesto de Asistencia a la Seguridad Social - IASS)
    Article 2, paragraph 1.a.iii:
    . Capital tax (Impuesto al Patrimonio - IP)
    Article 2, paragraph 1.b.iii.C
    . Value Added Tax - VAT (Impuesto al Valor Agregado - IVA)
    Article 2, paragraph 1.b.iii.D
    . Excise Tax (Impuesto Espec??fico Interno - IMESI)
    ANNEX B ??? Competent Authorities
    The Minister of Economy and Finance or his authorised repr??sentative.
    ANNEX C - Definition of the word "national" for the purpose of the Convention
    In relation to the Oriental Republic of Uruguay, the term ???national??? means any individual possessing Uruguayan nationality or citizenship and any legal person, association or other entity deriving its status as such front the laws in force in Uruguay.
    In accordance with Article 9, paragraph 3, of the Convention, the Oriental Republic of Uruguay declares its intention not to accept, as a general rule, the requests as are referred to in paragraph 1 of Article 9 of the Convention.
    Pursuant to Article 29, paragraph 1, of the Convention, the Oriental Republic of Uruguay declares that with respect to Uruguay, the Convention shall apply to the territory of Uruguay, including maritime and air space areas over which the State exercises sovereign rights and jurisdiction in accordance with international law and national law.

  • VANUATU
    Sitoutumispäivä: 23.08.2018 H
    Voimaantulopäivä: 01.12.2018
  • VIRO
    Sitoutumispäivä: 08.07.2014 R
    Voimaantulopäivä: 01.11.2014
  • YHDYSVALLAT
    Sitoutumispäivä: 13.02.1991 R
    Voimaantulopäivä: 01.04.1995
    Varauma:

    (1) The United States will not provide any form of assistance in relation to the taxes of other parties described in subparagraphs (b)(i) or (b)(iv) of paragraph 1 of Article 2 of the Convention (taxes imposed by or on behalf of possessions, political subdivisions, or local authorities) (as permitted by paragraph 1(a) of Article 30 of the Convention);

    (2) The United States will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for any tax, pursuant to Articles 11 through 16 of the Convention (as permitted by paragraph 1(b)of Article 30 of the Convention);

    (3) the United States will not provide assistance in the service of documents for any tax, pursuant to Article 17 of the Convention (as permitted by paragraph 1(d) of Article 30 of the Convention); this reservation does not apply to the service of documents by mail, pursuant to paragraph 3 of Article 17 of the Convention.


    Pursuant to Article 29, paragraph 1, this Convention shall apply to the United States of America, including Puerto Rico, the U.S. Virgin Islands, American Samoa, Guam, the Commonwealth of the Northern Mariana Islands, and any other territory or possession.

    Pursuant to Article 4, paragraph 3, of the Convention, the United States may inform the persons concerned before transmitting information to another party, in conformity with Article 5 or Article 7 of the Convention.

    ANNEX A (Article 2, paragraph 2, of the Convention)

    For the United States, this Convention shall apply to taxes imposed under Title 26 of the United States Code (the Internal Revenue Code of 1986), as amended, which correspond to the taxes in the categories referred to in paragraph 1.A and 1.B II and III of Article 2 of the Convention.

    ANNEX B (Article 3, paragraph 1.D, of the Convention)

    For the United States, the term "competent authority" means the Secretary of the Treasury or his designee.

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