Convention on Mutual Administrative Assistance in Tax Matters

Parties with reservations, declarations and objections

Party	Reservations / Declarations	Objections
Albania	Yes	No
Andorra	Yes	No
Antigua and Barbuda	Yes	No
Argentina	Yes	No
Armenia	Yes	No
Australia	Yes	No
Austria	Yes	No
Azerbaijan	Yes	Yes
Bahamas	Yes	No
Bahrain	Yes	No
Barbados	Yes	No
Belgium	Yes	No
Belize	Yes	No
Benin	Yes	No
Bosnia and Herzegovina	Yes	No
Botswana	Yes	No
Brazil	Yes	No
Brunei	Yes	No
Bulgaria	Yes	No
Burkina Faso	Yes	No
Cabo Verde	Yes	No
Cameroon	Yes	No
Canada	Yes	No
Chile	Yes	No
China	Yes	No
Colombia	Yes	No
Cook Islands	Yes	No
Costa Rica	Yes	No
Croatia	Yes	No
Cyprus	Yes	No
Czech Republic	Yes	No
Denmark	Yes	No
Dominica	Yes	No
Dominican Republic	Yes	No
Ecuador	Yes	No
El Salvador	Yes	No
Estonia	Yes	No
Eswatini	Yes	No
Finland	Yes	No
France	Yes	No
Georgia	Yes	No
Germany	Yes	No
Ghana	Yes	No
Greece	Yes	No
Grenada	Yes	No
Guatemala	Yes	No
Hungary	Yes	No
Iceland	Yes	No
India	Yes	No
Indonesia	Yes	No
Ireland	Yes	No
Israel	Yes	No
Italy	Yes	No
Jamaica	Yes	No
Japan	Yes	No
Jordan	Yes	Yes
Kazakhstan	Yes	No
Kenya	Yes	No
Kuwait	Yes	No
Latvia	Yes	No
Lebanon	Yes	No
Liberia	Yes	No
Liechtenstein	Yes	No
Lithuania	Yes	No
Luxembourg	Yes	No
Malaysia	Yes	No
Maldives	Yes	No
Malta	Yes	No
Marshall Islands	Yes	No
Mauritania	Yes	No
Mauritius	Yes	No
Mexico	Yes	No
Moldova	Yes	No
Monaco	Yes	No
Mongolia	Yes	No
Montenegro	Yes	No
Morocco	Yes	No
Namibia	Yes	No
Nauru	Yes	No
Netherlands, the Kingdom of the	Yes	No
New Zealand	Yes	No
Nigeria	Yes	No
Niue	Yes	No
North Macedonia	Yes	No
Norway	Yes	No
Oman	Yes	No
Pakistan	Yes	No
Panama	Yes	No
Papua New Guinea	Yes	No
Paraguay	Yes	No
Peru	Yes	No
Poland	Yes	No
Portugal	Yes	No
Qatar	Yes	No
Republic of Korea, the	Yes	No
Romania	Yes	No
Russian Federation	Yes	No
Rwanda	Yes	No
Saint Kitts and Nevis	Yes	No
Saint Lucia	Yes	No
Saint Vincent and the Grenadines	Yes	No
Samoa	Yes	No
San Marino	Yes	No
Saudi Arabia	Yes	No
Senegal	Yes	No
Serbia	Yes	No
Seychelles	Yes	No
Singapore	Yes	No
Slovakia	Yes	No
Slovenia	Yes	No
South Africa	Yes	No
Spain	Yes	No
Sweden	Yes	No
Switzerland	Yes	No
Thailand	Yes	No
Tunisia	Yes	No
Türkiye	Yes	Yes
Uganda	Yes	No
Ukraine	Yes	No
United Arab Emirates	Yes	No
United Kingdom	Yes	No
United States of America	Yes	No
Uruguay	Yes	No
Vanuatu	Yes	No
Vietnam	Yes	No

Albania

08-08-2013

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

01-02-2016

Annex B – Competent Authorities
In Andorra, the term “competent authority” means the Minister of Finance or his autorised representative.
Currently, the persons responsible are:
- H.E. Mr Jordi Cinca, Minister of Finance,
- Mrs Claudia Cornella, Secretary of State of International Financial Affairs

25-08-2016

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. 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 and Barbuda

16-10-2018

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:
None
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.

16-10-2018

Argentina

13-09-2012

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.
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,
Simplified Regime for Taxpayers (Monotributo).
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.

04-10-2018

31-10-2018

Armenia

06-02-2020

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

30-08-2012

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.
Annex B - Competent authorities
In relation to Australia, the term "competent authority" means the Commissioner of Taxation or an authorized representative of the Commissioner.
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.
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.

03-11-2017

Austria

28-08-2014

Pursuant to paragraph 1.a of Article 30 of the Convention, the Republic of Austria 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 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 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, the Republic of Austria 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.c of Article 30 of the Convention, the Republic of Austria 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 Austria.
Pursuant to paragraph 1.d of Article 30 of the Convention, the Republic of Austria reserves the right not to provide assistance in the service of documents for the taxes listed in the reservation made pursuant to paragraph 1.a of Article 30 of the Convention.
Pursuant to paragraph 1.f of Article 30 of the Convention, the Republic of Austria 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.
Annex A - Existing taxes to which the Convention shall apply
Article 2, paragraph 1.a.i
- income tax (Einkommensteuer)
- corporation tax (Körperschaftsteuer)
Article 2, paragraph 1b.iii. C
- value-added tax (Umsatzsteuer).
Annex B - Competent Authorities
In relation to the Republic of Austria, the term "competent authority" means the Federal Minister for Finance or his authorised representative.
Annex C - Definition of a "national" for the purpose of the Convention
None.

15-11-2018

Azerbaijan

03-06-2004

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 withheld 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 B - Competent authorities:
Ministry of taxes, State Customs Committee, Ministry of Labour and Social Protection of Population, Ministry of Finance.
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.

29-05-2015

Pursuant to Article 4, paragraph 3, of the Convention on Mutual Administrative Assistance in Tax Matters, according to the national legislation of the Republic of Azerbaijan, its competent authorities may inform its resident or national before transmitting information concerning him, in conformity with Article 5 and Article 7 of the Convention.
The Republic of Azerbaijan will apply the provisions of the Convention and the Protocol only in respect of the States Parties with which the Republic of Azerbaijan has diplomatic relations.

Objection Cyprus, 29-02-2016

The Republic of Cyprus 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, limiting the implementation of the provisions of the Convention and Protocol only to the States with which the Republic of Azerbaijan has diplomatic relations. The aforesaid declaration is contrary to the object and purpose of the Convention as it precludes the realisation of the cooperation foreseen by the Convention between all member States of the Council of Europe, one of which is the Republic of Cyprus, and as such, the said reservation is invalid.

Objection Armenia, 06-02-2020

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.

Bahamas

26-04-2018

In accordance with Article 30, paragraph 1.a, of the Convention, The Bahamas does 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, provided that it has not included any domestic tax in that category under Annex A of the Convention.
In accordance with Article 30, paragraph 1.b, of the Convention, The Bahamas does 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 of Article 2.
In accordance with Article 30, paragraph 1.c, of the Convention, The Bahamas does 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 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.
In accordance with Article 30, paragraph 1.d, of the Convention, The Bahamas does not provide assistance in the service of documents for all taxes listed in paragraph 1 of Article 2.
In accordance with Article 30, paragraph 1.e, of the Convention, The Bahamas does not permit the service of documents through the post as provided for in paragraph 3 of Article 17.
In accordance with Article 30, paragraph 1.f, of the Convention, The Bahamas applies Article 28, paragraph 7, 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 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.b.ii:
Compulsory social security contributions payable to general government.
Article 2, paragraph 1.b.iii.B:
Taxes on immovable property.
Article 2, paragraph 1.b.iii.C:
General consumption taxes, such as value-added or sales taxes.
Article 2, paragraph 1.b.iii.D:
Specific taxes on goods and services such as excise taxes.
Article 2, paragraph 1.b.iii.E:
Taxes on the use or ownership of motor vehicles.
Annex B – Competent Authorities
The Minister of Finance or his authorised representative.
Annex C – Definition of the term "national" for the purpose of the Convention
In The Bahamas the term “national” is used when there is a reference to a person (whether natural person or legal person) in the international arena, for example, a “national” of The Bahamas or a “National” of a State. However, when referring to a person domestically (in the domestic legislation) a person is considered a citizen, not a national.

26-04-2018

Bahrain

03-05-2018

Pursuant to paragraph 1.a of Article 30 of the Convention, the Kingdom of Bahrain reserves the right not to provide any form of assistance with respect to the taxes of other State Parties to the Convention in any of the categories listed in paragraph 1.b of Article 2 of the Convention, which are not included in Annex A of the Kingdom of Bahrain.
Pursuant to paragraph 1.b of Article 30 of the Convention, the Kingdom of Bahrain 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.d of Article 30 of the Convention, the Kingdom of Bahrain reserves the right not to provide assistance in the service of documents for all taxes listed in paragraph 1 of Article 2.
Pursuant to paragraph 1.f of Article 30 of the Convention, the Kingdom of Bahrain 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 Kingdom of Bahrain, 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 Kingdom of Bahrain.
The Kingdom of Bahrain declares that, in accordance with paragraph 3 of Article 4 of the Convention, the competent authority of the Kingdom of Bahrain may, when applying Articles 5 and 7 of the Convention, inform its citizens and residents before sending information concerning them.
The Kingdom of Bahrain declares its intention, as a general rule, in accordance with paragraph 3 of Article 9 of the Convention, not to accept applications from applicant States that allows the presence of representatives of its competent authority in the appropriate part of the tax examination in the Kingdom of Bahrain.
The Kingdom of Bahrain declares that the Convention shall apply to all parts of the territory of the Kingdom of Bahrain and shall include the Kingdom’s territory, subsoil, territorial waters adjacent to it, its seabed and all of which the Kingdom’s sovereignty and jurisdiction is exercised in accordance with principals of international law.
Annex A – Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i: Income tax established by Legislative Decree No. 22 for the year 1979.
Annex B – Competent Authorities
The Minister of Finance or his authorised representative.

11-05-2018

Barbados

28-10-2015

Pursuant to Article 3, paragraph 1.d, of the Convention, for Barbados, the term “competent authority” means the Barbados Revenue Authority.

04-07-2016

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.

15-12-2017

Belgium

01-08-2000

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.

28-09-2017

Belize

29-05-2013

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.
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.
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.
Annex B - Competent Authorities
In relation to Belize, the term "competent authority" means the Financial Secretary in the Ministry of Finance.
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.

Benin

24-01-2023

In accordance with Article 30, paragraph 1.a, of the Convention, the Republic of Benin reserves the right not to provide any form of assistance in relation to the taxes of other Parties in the following categories of 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,
B. taxes on immovable property,
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.f, of the Convention, the Republic of Benin 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 Benin, 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 Republic of Benin.
The Republic of Benin 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:
- Corporation tax (IS);
- Business Income Tax (IBA);
- Tax on income from movable capital (IRCM);
- Property income tax (IRF);
- Tax on real estate capital gains (TPVI);
- Tax on wages and salaries (ITS).
Article 2, paragraph 1.a.ii: NONE
Article 2, paragraph 1.b.iii.C: Value Added Tax.
Article 2, paragraph 1.b.iii.D:
- Tax on financial and insurance activities (TAFA);
- Excise Taxes:
- Tax on specific products;
- Single specific tax on petroleum products;
- Tax on passenger vehicles.
Article 2, paragraph 1.b.iii.E: Tax on motor vehicles.
ANNEX B – Competent Authorities
The Minister for Economy and Finance or the Director General for Taxes.

Bosnia and Herzegovina

21-09-2020

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 Brčko District Finance Directorate for the territory of the Brčko District; For taxes referred to in Article 2, paragraph 1, subparagraph b.iii.C, the competent authority shall be the Indirect Taxation Authority.

Botswana

15-06-2021

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.
ANNEX B – Competent Authorities
The Minister responsible for finance represented by the Commissioner General of the Botswana Unified Revenue Service (BURS) or an authorised representative of the Commissioner General.
ANNEX C – Definition of a “national” for the purpose of the Convention
Any individual possessing the nationality or citizenship of Botswana and any legal person, association, or other entity deriving its status as such from the laws in force in Botswana.

Brazil

01-06-2016

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 service of documents through the post, as provided for in paragraph 3 of Article 17 of the Convention.
Annex A - Taxes to which the Convention applies
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: Tax on Industrialized Products;
d) paragraph 1.b.iii.G: any other taxes administered by the Secretariat of the Federal Revenue of Brazil.
Annex B – Competent Authorities
The Competent Authority for the Federative Republic of Brazil is the Secretary of the Federal Revenue of Brazil.

23-03-2017

29-03-2018

Brunei

28-03-2019

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.

02-01-2020

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

14-03-2016

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.

30-11-2017

Burkina Faso

13-12-2022

In accordance with Article 30, paragraph 1.a, of the Convention, Burkina Faso will not provide any form of assistance in relation to the taxes of other Parties in any of the categories mentioned in Article 2, paragraph 1.b, of the Convention.
In accordance with Article 30, paragraph 1.e, of the Convention, Burkina Faso will not permit the service of documents through the post as provided for in Article 17, paragraph 3, of the Convention.
Burkina Faso 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.
Article 2, paragraph 1.a.ii: Capital gains tax.
ANNEX B – Competent Authorities
The Minister responsible for Finance and the Director General for Taxes.
In accordance with Article 9, paragraph 3, of the Convention, Burkina Faso declares that the competent authority of Burkina Faso reserves the right to not accept, as a general rule, requests of the competent authority of the applicant State to be present at the appropriate part of a tax examination in the requested State, namely Burkina Faso.

Cabo Verde

06-01-2020

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 alienaçao 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.

Cameroon

30-06-2015

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Cameroon will not provide any form of assistance in relation to the taxes of other Parties in 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,
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,
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 Cameroon will not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
For the purposes of this Convention, the territory of Cameroon means the territory of the Republic of Cameroon including the territorial sea and beyond it any areas outside the territorial waters of Cameroon on which in accordance with international law, Cameroon has sovereign rights for the purpose of exploitation of natural resources of the seabed and its subsoil and underlying waters.
Annex A – Taxes to which the Convention would apply
Article 2, paragraph 1.a.i
- Personal income Tax,
- Corporate income tax ;
- Special tax on income;
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.C
- Value-added tax;
Article 2, paragraph 1.b.iii.D
- Excise tax
Annex B – Competent Authorities
The Minister of Finance or its representative.
Annex C – Definition of the word "national" for the purpose of the Convention
All individuals of Cameroonian nationality and all legal persons, partnership or capital companies, associations and other entities planned and constituted under the laws in force in Cameroon.

Canada

21-11-2013

Canada will not provide any form of assistance in relation to the taxes of other Parties described in any of sub-paragraphs 1(b)(i), (ii), (iii) A, B, E, F and G and (iv) of Article 2 of the Convention (as permitted by sub-paragraph 1(a) of Article 30 of the Convention).
Canada 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 sub-paragraph 1(b) of Article 30 of the Convention).
Canada will not provide assistance in the service of document for any tax, pursuant to Article 17 of the Convention (as permitted by sub-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.
Annex A - Taxes to which the Convention would apply:
Article 2, paragraph 1(a): the taxes on income or profits, including capital gains that are added to income at a rate determined under the following act, and taxes on net wealth that are imposed on behalf of Canada under the Income Tax Act (Canada).
Article 2, paragraph 1(b)(iii) C: the Value Added Tax imposed on behalf of Canada under Part IX of the Excise Tax Act (Canada).
Article 2, paragraph 1(b)(iii) D: the taxes imposed on behalf of Canada under Parts I and III of the Excise Tax Act (Canada) and the Excise Act, 2001 (Canada).
Annex B - Competent Authorities
The Minister of National Revenue or the Minister's authorised representative.
Annex C - Definition of a "national" for the purpose of the Convention
None.

Chile

02-06-2015

Annex B - Competent Authorities
The Minister of Finance, the Commissioner of the Chilean Internal Revenue Service, and their authorised representatives.

07-07-2016

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.

China

16-10-2015

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.i, 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.

18-05-2018

In accordance with the Basic Law of the Macao Special Administrative Region of the People’s Republic of China, the Government of the PRC decides that the Convention applies to the Macao Special Administrative Region of the PRC and declares that:
The three reservations pursuant to paragraphs 1.b, 1.d and 1.e of Article 30 of the Convention made by the PRC shall apply to the Macao Special Administrative Region
The reservation pursuant to paragraph 1.a of Article 30 and the three declarations pursuant to paragraph 1 of Article 2, paragraph 1.d of Article 3 and paragraph 3 of Article 4 of the Convention made by the PRC shall not apply to the Macao Special Administrative Region.
Pursuant to Article 30, paragraph 1.a, of the Convention, the Macao Special Administrative Region shall not provide any form of assistance in relation to taxes of the other Parties described in sub-paragraphs b.i, b.ii, b.iii.A, b.iii.C, b.iii.F and b.iv of paragraph 1 of Article 2 of the Convention.
Pursuant to Article 4, paragraph 3, of the Convention, the Macao Special Administrative Region may inform its resident 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 Macao Special Administrative Region will not accept, as a general rule, such requests as are referred to in paragraph 14 of Article 9 of the Convention.
Annex A - Taxes to which the Convention applies
For the Macao Special Administrative Region, the Convention shall apply to the following taxes imposed under the laws of the Macao Special Administrative Region administered by its tax authority:
Article 2, paragraph 1.a.i:
- Profits tax (Impost Complementar de Rendimentos)
- Salaries tax (Imposto Profissional)
- Urban Property Tax (Contribuição Predial Urbana)
Article 2, Paragraph 1.b.iii.B
- Stamp Duty (Imposto do Selo)
Article 2, Paragraph 1.b.iii.D
-Tourism Tax (Imposto de turismo)
Article 2, Paragraph 1.b.iii.E
- Motor Vehicle Tax (Imposto sobre Veículos Motorizados)
Article 2, Paragraph 1.b.iii.G
- Business Tax (Contribuição Industrial)
Annex B - Competent authorities
The competent authority for the Macao Special Administrative Region is the Chief Executive of the Macao Special Administrative Region or his authorized representative.

21-05-2018

In accordance with the Basic Law of the Hong Kong Special Administrative Region of the People’s Republic of China, the Government of the PRC decides that the Convention applies to the Hong Kong Special Administrative Region (Hong Kong SAR) of the PRC and declares that:
The three reservations pursuant to paragraphs 1.b, 1.d and 1.e of Article 30 of the Convention made by the PRC shall apply to the Hong Kong SAR.
The reservation pursuant to paragraph 1.a of Article 30 and the three declarations pursuant to paragraph 1 of Article 2, paragraph 1.d of Article 3 and paragraph 3 of Article 4 of the Convention made by the PRC shall not apply to Hong Kong SAR.
Pursuant to Article 30, paragraph 1.a, of the Convention, the Hong Kong SAR shall not provide any form of assistance in relation to taxes of the other Parties described in paragraph 1.b of Article 2 of the Convention.
Pursuant to Article 30, paragraph 1.c, of the Convention, the Hong Kong SAR 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 the Hong Kong SAR or, where a reservation has previously been made
paragraph 1.a or 1.b 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.f, of the Convention, the Hong Kong SAR 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 the Hong Kong SAR, 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 the Hong Kong SAR.
Pursuant to Article 4, paragraph 3, of the Convention, the Hong Kong SAR may inform its resident or national before transmitting information concerning that resident or national to another Party, in conformity with Article 5 of the Convention.
Pursuant to Article 9, paragraph 3, of the Convention, the Hong Kong SAR will not 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 applies
For the Hong Kong SAR, the Convention shall apply to the following taxes imposed under the laws of the Hong Kong SAR administered by its tax authority:
Article 2, paragraph 1.a.i:
- Profits tax
- Salaries tax
- Property Tax
Annex B - Competent authorities
The competent authority for the Hong Kong SAR is the Commissioner of Inland Revenue of the Government of the Hong Kong SAR or the authorised representative of the Commissioner.
Annex C – Definition of the term "national" for the purpose of the Convention
For the application of the Convention to the Hong Kong SAR, paragraph 1.e of Article 3 of the Convention refers to any person having the right to abode, or is incorporated or otherwise constituted in the Hong Kong SAR.

25-06-2018

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 Hong Kong Special Administrative Region of the People’s Republic of China (hereafter “the Hong Kong SAR”) 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”), the Hong Kong SAR has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 20 March 2018;
[...]
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.
The People’s Republic of China 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 Hong Kong SAR 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 People’s Republic of China declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between the Hong Kong SAR 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.

Colombia

19-03-2014

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Colombia 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 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. 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 Republic of Colombia reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all the taxes.
Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Colombia reserves the right not to provide assistance in the service of documents for all taxes.
Annex A - Existing taxes to which the Convention shall apply:
The existing taxes to which the Convention shall apply within the Colombian legal system are:
Article 2, paragraph 1.a.i:
- income tax and its complementary taxes ;
- Pro equity income tax - CREE;
Article 2, paragraph 1.a.ii:
- income tax and its complementary taxes ;
Article 2, paragraph 1.a.iii:
- tax on capital ;
Article 2, paragraph 1.b.i :
Not applicable ;
Article 2, paragraph 1.b.ii :
Not applicable ;
Article 2, paragraph 1.b.iii.A :
- income tax and complementary taxes ;
Article 2, paragraph 1.b.iii.B :
Not applicable ;
Article 2, paragraph 1.b.iii.C :
- value added tax - VAT ;
Article 2, paragraph 1.b.iii.D :
- national consumption tax ;
Article 2, paragraph 1.b.iii.E :
Not applicable ;
Article 2, paragraph 1.b.iii.F :
Not applicable ;
Article 2, paragraph 1.b.iii.G :
Not applicable.
Annex B - Competent Authorities
The competent authority for the Republic of Colombia is the Director General of the National Tax and Customs Administration (Director General de la Dirección de Impuestos y Aduanas Nationales - DIAN) or his autorised representative.

20-12-2017

Cook Islands

29-05-2017

Annex A - Taxes to which the Convention would apply
Article 2, paragraph 1.a.i:
- Taxes on income or profits, including withholding taxes
Article 2, paragraph 1.b.iii.C:
- Value Added Tax
Article 2, paragraph 1.b.iii.D:
- Excise Taxes on alcohol and sugar
Annex B - Competent authorities
The Treasurer of Revenue Management or his authorised representative.

Costa Rica

05-04-2013

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.
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.
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.
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.
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.
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.
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 vehículos, embarcaciones y aeronaves).
Annex B - Competent Authorities
The Director of the Tax Administration (Director General de Tributación).

09-11-2018

Croatia

28-02-2014

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Croatia 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. A. estate, inheritance or gift taxes,
iii. B. taxes on immovable property,
iii. D. specific taxes on goods and services such as excise taxes,
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 Croatia 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 Croatia 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 Croatia, 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 the Republic of Croatia.
Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Croatia 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.
Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of Croatia 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 Croatia, 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 Croatia.
Annex A - Existing taxes to which the Convention shall apply:
For the Republic of Croatia, the Convention shall apply to those taxes in Article 2, paragraph 1, of the Convention which fall within:
Article 2, paragraph 1.a.i:
- tax on income (porez na dohodak) ;
- tax on profits (porez na dobit).
Article 2, paragraph 1.b.iii :
C: - value-added Tax (porez na dodanu vrijednost);
G: - real estate transaction tax (porez na promet nekretnina).
Annex B - Competent Authorities
In relation to the Republic of Croatia, the term "competent authority" means the Ministry of Finance or its authorised representative.

Cyprus

19-12-2014

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Cyprus will not provide any form of assistance in relation to the following taxes of other Parties described in Article 2, paragraph 1.b:
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;
Sub-paragraph b.ii: Compulsory social security contributions payable to general government or to social security institutions established under public law;
Sub-paragraph b.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;
Sub-paragraph 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.b, of the Convention, the Republic of Cyprus 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 29, paragraph 1, of the Convention, the term Cyprus means the Republic of Cyprus and, when used in a geographical sense, includes the national territory, the territorial sea thereof as well as any area outside the territorial sea, including the contiguous zone, the exclusive economic zone and the continental shelf, which has been or may hereafter be designated, under the laws of Cyprus and in accordance with international law, as an area within which Cyprus may exercise sovereign rights or jurisdiction.
Annex A - Existing taxes to which the Convention shall apply
Article 2, paragraph 1.a.i:
- income tax;
- corporate income tax;
- special contribution for the defence of the Republic;
Article 2, paragraph 1.a.ii:
- capital gains tax.
Article 2, paragraph 1.b.iii:
B. Tax on Immovable Property;
C. Value Added Tax.
Annex B - Competent Authorities
The Minister of Finance or his autorised representative.
Annex C - Definition of the word "national" for the purposes of the Convention
i. any individual possessing the citizenship of Cyprus;
ii. any legal person, partnership or association deriving its status as such from the laws in force in the Republic of Cyprus.

12-10-2018

26-03-2019

The Republic of Cyprus has examined the Declaration contained in the instrument of ratification deposited by the Republic of Turkey with the Secretary General of the OECD on 26 March 2018, upon ratification of the Convention on Mutual Administrative Assistance in Tax Matters of 25th January 1988, (No.127).
The Republic of Turkey declares that its ratification of the Convention on Mutual Administrative Assistance in Tax Matters of 25th January 1988, (No.127) neither amounts to any form of recognition of the Republic of Cyprus, as party to that Convention, nor should it imply any obligation on the part of the Republic of Turkey to enter into any dealing with the Republic of Cyprus within the framework of the said Convention.
In the view of the Republic of Cyprus, the content and purported effect of this Declaration makes it tantamount in its essence to a reservation contrary to the object and purpose of the Convention. By such Declaration, the Republic of Turkey purports to evade its obligations under the Convention vis-à-vis another equal and sovereign State Party, namely the Republic of Cyprus. Indeed, the Declaration prevents the realization of cooperation between State Parties foreseen by the Convention.
The Republic of Cyprus therefore strongly rejects the aforesaid Declaration made by the Republic of Turkey and considers such declaration to be null and void. The aforementioned objections by the Republic of Cyprus shall not preclude the entry into force of the Convention, in their entirety, between the Republic of Cyprus and the Republic of Turkey.
Regarding the Republic of Turkey’s pretension, as expressed in the same Declaration, that “the Republic of Cyprus is defunct and that there is no single authority which in law or in fact is competent to represent jointly the Turkish Cypriots and the Greek Cypriots and consequently Cyprus as a whole”, the Republic of Cyprus would like to remind of the following:
Despite, being, through binding international agreements, a guarantor of “the independence, territorial integrity and security of the Republic of Cyprus” (Article II of the 1960 Treaty of Guarantee), the Republic of Turkey illegally invaded Cyprus in 1974 and continues since then occupying 36.2% of the territory of the Republic.
The illegality of such aggression was made manifested by the U.N. Security Council Resolutions 541 (1983) and 550 (1984). Resolution 541’s operative paragraph 2 considers “the declaration [of the Turkish Cypriot authorities of the purported secession of part of the Republic of Cyprus] as legally invalid and “calls for its withdrawal”. Paragraph 6 then “calls upon all States to respect the sovereignty, independence, territorial integrity and non-alignment of the Republic of Cyprus” and further at par. 7 “calls upon all States not to recognize any Cypriot state other than the Republic of Cyprus”. Resolution 550, operative para. 2, also ”condemns all secessionist actions, including the purported exchange of Ambassadors between Turkey and the Turkish Cypriot leadership, declares them illegal and invalid, and calls for their immediate withdrawal”. Para. 3 then “reiterates the call upon all States not to recognize the purported state of the “Turkish Republic of Northern Cyprus” set up by secessionist acts and calls upon them not to facilitate or in any way assist the aforesaid secessionist entity”.
The European Court of Human Rights additionally, in its Judgment of 10th May 2001 on the Fourth Interstate Application of Cyprus v. Turkey, found, at para. 77, that Turkey, which has ”effective control over northern Cyprus“, is responsible for securing all human rights under the European Convention on Human Rights and for violations of such rights by her own soldiers or officials, or by the local administration, which are imputable to Turkey. The responsibilities of the occupying power emanate from international humanitarian law, including the Fourth Geneva Convention.
Turkey is responsible for the policies and actions of the “TRNC” because of the effective control she exercises through her army. Her responsibility is engaged by virtue of the acts of the local administration, which survives by virtue of Turkish military and other support (Cyprus v. Turkey, Judgment, 10 May 2001, at pp. 20-21, reiterating Loizidou). From the judgments of the European Court of Human Rights and the Security Council Resolutions on Cyprus, it is evident that the international community does not regard the “TRNC” (Turkey’s subordinate local administration in occupied Cyprus, condemned in the strongest terms by the Security Council ) as a State under international law (Cyprus v. Turkey, 10 May 2001, para. 61). In contrast, the Republic of Cyprus has repeatedly been held to be the sole legitimate Government of Cyprus, contrary to Turkey’s assertions about that Government, which Turkey calls “the Greek Cypriot Administration” with pretences “to represent the defunct Republic”. The Turkish assertions constitute a propaganda ploy to divert attention from Turkey’s responsibility for the violations in occupied Cyprus. Turkey’s assertions and her assorted objections to the Republic of Cyprus’ authority, jurisdiction and sovereignty, and her claims on behalf of the Turkish Cypriots and the “TRNC”, have repeatedly been rejected by the international community and relevant judicial bodies where such claims were fully argued and then rejected in Cyprus’s pleadings. Misrepresentations about the treatment of Turkish Cypriots by the Government of Cyprus were made. (These claims were repeated in Turkey’s current Declaration). In fact, the European Court of Human Rights and the Commission accepted Cyprus arguments and refutation of Turkish assertions and exaggerations about the period prior to Turkey’s invasion of Cyprus in July 1974. It refused to pronounce on Turkey’s version of the ejection of Turkish Cypriots from offices of State (there was in fact a Turkish boycott).
It is now time for the relevant pronouncement in Resolutions and the decisions therein, as well as in judgments of the European Court of Human Rights to be heard and acted upon. The Court itself insisted in its 12 May 2014 Just Satisfaction Judgment that this must happen once the Court had spoken (Cyprus v. Turkey, p. 23 Joint Concurring Judgment of nine Judges). It should be emphasized that, the Security Council repeatedly reaffirmed all its relevant Resolutions on Cyprus, having, over several decades and reiterated their content.
Nevertheless, the Republic of Turkey, not only flagrantly holds in contempt all relevant U.N. Resolutions, International Law rules and the U.N. Charter on the matter, but furthermore she continues violating international legality, by systematically questioning the legitimacy of the Republic of Cyprus and further promoting the illegal secessionist entity in the occupied part of the Republic of Cyprus, including through declarations, as the one at hand.

Czech Republic

11-10-2013

The Czech Republic, in order to ensure unequivocal interpretation of Article 22, paragraph 2, of the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 Protocol, declares that it interprets Article 22, paragraph 2, of the Convention as amended by the 2010 Protocol, as not establishing any automatic right of the requesting State to use information received in accordance with the Convention as amended by the Protocol as evidence in criminal proceedings, but information received in accordance with the Convention as amended by the Protocol may be used by the requesting State in criminal proceeding as evidence only if judicial authorities of the requested State or any other authorities of the requested State competent under the laws of the requested State give consent to it in accordance with applicable international treaties on mutual legal assistance in criminal matters and the domestic law of the requested State concerning providing mutual legal assistance in criminal matters.
Annex A - Existing taxes to which the Convention shall apply:
Article 2, paragraph 1.a.i:
- Personal income tax
- Corporate income tax
- Levy on lotteries and other similar games
Article 2, paragraph 1.b.ii:
- Public health insurance and social security insurance and a contribution to the state employment policy
Article 2, paragraph 1.b.iii.B:
- Real estate tax, tax on acquisition of real estate
Article 2, paragraph 1.b.iii.C:
- Value-added Tax
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 natural gas and some other gases, tax on solid fuels, tax on electricity
Article 2, paragraph 1.b.iii.E:
- Road tax.
Annex B - Competent Authorities
The Minister of Finance or his authorised representative;
The Czech Social Security Administration in relation to compulsory social security contributions and a contribution to the state employment policy;
The Center for International Reimbursements in relation to compulsory public health insurance contributions.

12-02-2019

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:
Article 2, paragraph 1.a.i.:
- Personal income tax;
- Corporation income tax;
- Gambling tax;

Date of effect of the declaration: 1 June 2019.

15-03-2019

09-10-2020

In accordance with Article 2, paragraph 3, of the Convention […], 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.

Denmark

16-07-1992

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 exploiting the natural resources of the seabed or its sub-soil and the superjacent waters and with regard to other activities for the economic exploration and exploitation of the area.
Annex B
Denmark (except for Greenland)
The Minister for Taxation of his authorised representative,
Greenland
The Local Government or its authorised representative.

28-09-2001

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 (ejendomsværdiskat),
church tax (kirkeskat)
ii.: labour market contribution (arbejdsmarkedsbidrag),
special pension contribution (særligt pensionsbidrag)
iii. A: tax on inheritance and gifts (afgift af dødsboer og gaver)
iii. B: --
iii. C: value added tax (merværdiafgift),
iii. D: excise duties imposed by the State (forbrugsafgifter, som pålægges af staten)
iii. E: registration tax on motor vehicles (registreringsafgift af motorkøretøjer), weight tax on motor vehicles and other taxes on the ownership or use of motor vehicles (vægtafgift af motorkøretøjer og andre afgifter på oje eller brug af motorkøretøjer)
iii. F: tax on insurances for yachts (afgift af lystfartøsforsikringer)
iii. G: payroll tax (lømsumsafgift),
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 (dækningsafgift af forretningsejendom),
property release tax (frigørelsesafgift)
Greenlandic taxes:
Article 2, paragraph 1.a.
i.: income tax to the Greelandic home rule Government (landsskat, særlig landsskat),
dividend tax (udbytteskat),
company tax (selskabsskat)
Article 2, paragraph 1.b.
i.: municipal tax (kommuneskat),
common municipal tax (fælleskommunal 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 (indførselsafgift)
iii. D: tax on gambling machines (afgift af automatspil),
harbour duty (havneafgift),
tax on sea transport of goods to, from and within Greenland (afgift på søtransport af gods til, fra og I Grønland),
tax on shrimps (afgift på rejer)
iii. E: tax on motor vehicles (afgift af motorkøretøjer)
iii. G: tax on lottery (lotteriafgift),
stamp duty (stempelafgift).

10-11-2006

Annexes A and B to the Convention are [...] supplemented.
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 nýtslugjaldi)
taxes levied under the Hydrocarbon Tax Act (skattur eftier kolvetnisskattalógini)
taxes levied under the Tonnage Tax Act (skattur eftir tonnsaskattalógini)
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 (arbeiðsmarknareftirlønargjald)
iii.C: value added tax (meirvirðisgjald)
iii. D: import and excise duties (tollur)
iii.E: registration tax on motor vehicles (skrásetingargjald)
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 (tinglýsingargjald)
Annex B - Competent Authority
Faroe Islands
The Faroe Islands Customs and Tax Administration (Toll- og Skattstova Føroya).

05-04-2017

Dominica

30-04-2019

Annex A - Taxes to which the Convention would apply
Article 2, paragraph 1.a.i:
- Personal Income Tax;
- Corporate Tax;
- Withholding Tax.
Article 2, paragraph 1.a.iii.B: Land Transfer Fees.
Article 2, paragraph 1.a.iii.C: Value Added Tax.
Article 2, paragraph 1.a.iii.D: Excise Tax.
Article 2, paragraph 1.a.iii.E:
- Motor Vehicle License Fees;
- Highway Maintenance Levy.
Article 2, paragraph 1.a.iii.G:
- Stamp Duties;
- Import Duties.
Annex B - Competent authorities
The Minister for Finance or its authorised representative.

20-05-2019

Dominican Republic

06-09-2019

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. 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.

17-08-2023

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.
Considering that Dominican Republic intends to start automatically exchanging Country by Country Reports as of 2018 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”), Dominican Republic has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on July 6th 2023;
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;
Dominican Republic declares that the amended Convention shall have effect in accordance with the terms of the CbC MCAA for administrative assistance under the CbC MCAA between Dominican Republic 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

26-08-2019

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 (participación laboral en las utilidades de titulares de derechos mineros, atribuibles al Estado)
- Mineral exploitation royalties (Regalías a la explotación 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 artículo 408 de la Constitución, correspondiente a la explotación 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 único a la utilidad en la enajenación de acciones, participaciones, otros derechos representativos de capital u otros derechos que permitan la exploración, explotación, concesión 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 análoga)
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 vehículos 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 plásticas no retornables)
- Mining concession conservation patents (Patentes de conservación 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.

01-09-2021

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 […] as amended by the Protocol amending the Convention […] (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

21-05-2019

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.
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.
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.
Annex A - Taxes to which the Convention would apply
Article 2, paragraph 1.a.i: Income Tax.
Article 2, paragraph 1.a.ii: Capital Gains Tax.
Article 2, paragraph 1.b.iii.B: Tax on the transfer of movable property.
Article 2, paragraph 1.b.iii.C: Value Added Tax (Tax on the transfer of immovable property and services).
Article 2, paragraph 1.b.iii.E: Special tax on the first registration of goods on the national territory.
Annex B - Competent authorities
The Director General of National Taxation.
Annex C - Definition of the word "national" for the purpose of the Convention
The term “national” refers to:
i. Any individual of Salvadoran nationality; and
ii. Any legal person deriving its status as such from the laws in force in El Salvador.

Estonia

08-07-2014

In accordance with Article 30, paragraph 1.a, of the Convention, the Republic of Estonia reserves the right not to provide any form of assistance in relation to the taxes of other Parties in the categories listed in Article 2, paragraph 1.b.i and iv (taxes imposed on behalf of local authorities or other political subdivisions).
Annex A - Existing taxes to which the Convention shall apply
Article 2, paragraph 1.a.i:
- income tax;
Article 2, paragraph 1.b.ii:
- social tax ;
- unemployment insurance premium ;
- contribution to mandatory funded pension;
Article 2, paragraph 1.b.iii:
B. land tax;
C. value-added tax;
D. excise duties;
E. heavy goods vehicles tax;
G. gambling tax.
Annex B - Competent Authorities
The Tax and Customs Board.

03-01-2019

Eswatini

16-03-2021

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.

Finland

11-04-2002

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 (yhteisöjen tulovero; inkomstskatten för samfund),
the tax withheld at source from non-residents' income (rajoitetusti verovelvollisen lähdevero; källskatten för begränsat skattskyldig),
the tax withheld at source from interest (korkotulon lähdevero; källskatten på ränteinkomst),
the withholding tax for foreign employees (ulkomailta tulevan palkansaajan lähdevero; källskatt för löntagare från utlandet),
(ii)
-
(iii)
the state capital tax (valtion varallisuusvero; den statliga förmögenhetsskatten),
Article 2, paragraph 1 (b):
(i)
the communal tax (kunnallisvero; kommunalskatten),
the church tax (kirkollisvero; kyrkoskatten),
the forestry duty (metsänhoitomaksu; skogsvårdsavgiften),
(ii)
the national pension insurance contribution (vakuutetun kansaneläkevakuutusmaksu; försäkrads folkpensionsförsäkringspremie),
the health insurance contribution (vakuutetun sairausvakuutusmaksu; försäkrads sjukförsäkringspremie),
the employer's social security contribution (työnantajan sosiaaliturvamaksu; arbetsgivares socialskyddsavgift),
(iii) A
the inheritance tax and the gift tax (perintövero ja lahjavero; arvsskatten och gåvoskatten),
(iii) B
-
(iii) C
the value added tax (arvonlisävero; mervärdesskatten),
(iii) D
the excise duty on tobacco (tupakkavero; tobaksaccisen),
the excise duty on soft drinks (virvoitusjuomavero; läskedrycksaccisen),
the excise duty on liquid fuels (nestemäisten polttoaineiden valmistevero; accisen på flytande bränslen),
the excise duty on electricity and certain energy sources (sähkön ja eräiden polttoaineiden valmistevero; accis på elström och vissa bränslen),
the excise duty on alcohol and alcoholic beverages (alkoholi- ja alkoholijuomavero; accisen på alkohol och alkoholdrycker),
the tax on certain insurance premiums (eräistä vakuutusmaksuista suoritettava vero; skatten på vissa försäkringspremier),
the oil waste duty (öljyjätemaksu; oljeavfallsavgiften),
the motor-car tax (autovero; bilskatten)
(iii) E
the tax on specific motor vehicles (moottoriajoneuvovero; motorfordonsskatten),
the fuel fee (polttoainemaksu; bränsleavgift),
the vehicle tax (ajoneuvovero; fordonsskatt),
(iii) F
-
(iii) G
the stamp duty (leimavero; stämpelskatten),
the oil damage duty (öljysuojamaksu, oljeskyddsavgiften),
the transfer tax (varallisuudensiirtovero; överlåtelseskatt),
the tax on lottery prizes (arpajaisvero; lotteriskatt),
the tax on waste (jätevero; avfallsskatt),
(iv)
the municipal tax on real property (kiinteistövero; fastighetsskatten)
Annex B - Competent authorities
Article 3, paragraph 2 (d):
The National Board of Taxes.

20-12-2017

07-09-2018

France

12-12-2007

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 Départements 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.
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 Île-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.
Annex B - Competent authorities
France declares that the competent authorities within 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 sécurité sociale - ACOSS) or the Chairman of the Administrative Council of the Agricultural Social Insurance Mutual Benefit Fund (Caisse centrale de mutualité 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.

20-12-2017

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.
Considering that the Government of the French Republic intends to start automatically exchanging Country-by-Country reports (“CbC Reports”) as of 2018 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”), it has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 27 January 2016;
[...]
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

08-03-2018

27-08-2018

The French Republic wishes to clarify the declaration transmitted on 25 May 2005, when it deposited its instrument of approval of the Convention, and confirmed on 18 October 2007, which reads as follows:
“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 Départements 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.”
In view of the various territorial reforms that have taken place since the issuance of this declaration, France wishes to clarify the scope of the expression "overseas departments of the French Republic": the Convention continues to apply to territorial authorities governed by Article 73 of the Constitution, namely Guadeloupe, Guyana, Reunion, Martinique and Mayotte.

27-08-2018

In conformity with Article 29, paragraph 2, of the convention, France declares that it extends the application of the Convention to New Caledonia, 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.
Annex A - Taxes to which the Convention would apply for New-Caledonia
Article 2, paragraph 1.a.:
i) Income tax;
- Additional contribution to the corporation tax
- Caledonian solidarity contribution
- Tax on civil companies and metallurgical and mining activities
ii) Tax on securities income
- tax on claims, deposits and guarantees
Article 2, paragraph 1.b.:
i) Not applicable;
ii) Additional contribution to the corporation tax
iii) A. - Registration fees
B. - Property tax on developed property
C. - General consumption tax
D. - Indirect contributions
E. - Not applicable
F. - Not applicable
G. - Tax on patents
- Telephone contribution
- Stamp duties and various taxes
- Registration fees and cadastral taxes
- License fees
- Entertainment and game revenue tax
- Electricity tax due by electric energy distributions
- Domestic consumption tax on local and locally manufactured products
- Tax on alcohols and tobaccos
- Fees and royalties applicable to mining authorisations and mining titles
- Employer contribution for vocational training
iv) Added percentages
- Tax on insurance agreements
- Taxation for the benefit of municipalities
- Taxation for the benefit of provinces
- Taxation for the benefit of the Chamber of Commerce and Industry and Crafts and Artisans Chamber
- Solidarity levy on services

Georgia

28-04-2011

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. -
Annex B - Competent authorities
The Ministry of Finance or its authorised representative.
Annex C - Definition of the word "national" for the purposes 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.

Germany

28-08-2015

In accordance with Article 30, paragraph 1.b, of the Convention, the Federal Republic of Germany reserves the right – with respect with all taxes, contributions and ancilliary payments listed in Article 2, paragraph 1, of the Convention – not to provide assistance in recovery in accordance with Articles 11 to 16 of Section II of the Convention.
I. Interpretative declaration by the Federal Republic of Germany.
The Federal Republic of Germany makes reference to the spirit and purpose of the Convention drafted under the auspices of the OECD and the Council of Europe: namely, to regulate the exchanges of data in purely tax-related procedures, with the aim of achieving better taxation. It is therefore the understanding of the Federal Republic of Germany that the Convention, in particular Article 4 thereof, covers only the exchange of data in purely tax-related matters, with the consequence that data transmitted on the basis of the Convention may not be used for other purposes, in particular for criminal proceedings that are not related solely to tax crimes, without the consent of the State transmitting the data. The Convention does not cover international legal assistance in criminal and civil matters.
In this connection, the Federal Republic of Germany would also like to emphasise that it is obligated – by its constitution, the Basic Law, by its public policy (ordre public), and as a Contracting Party to the European Convention on Human Rights and other fundamental instruments for the protection of human rights – to uphold minimum standards of human rights; accordingly, data will not be transmitted in proceedings that could lead to the imposition of death penalty or that threaten to violate minimum standards of human rights and due process.
The Federal Republic of Germany believes that its position in this regard is backed up by the Council of Europe’s legal stance on the prohibition of the death penalty and on compliance with minimum standards of human rights. As a result, the Federal Republic of Germany assumes that the present Convention, concluded under the auspices of the Council of Europe, may under no circumstances lead to the imposition of the death penalty or to the violation of minimum standards of human rights. Against this background, it follows that the Convention can be interpreted only in such a way that the data transmitted on the basis of the Convention may under no circumstances be used in proceedings that could lead to the imposition of the death penalty or to the violation of minimum standards of human rights.
II. Declaration on safeguards by the Federal Republic of Germany
With respect to Article 21 and Article 22 of the Convention, the Federal Republic of Germany declares that it shall consider itself obligated to transmit tax data relating to individuals or companies (hereinafter referred to as “data”) only if the receiving Party (hereinafter referred to as the “receiving agency”) complies with the following safeguards:
1. The receiving agency may use the data in compliance with Article 22 and shall be subject to the conditions prescribed by the transmitting agency. The use of data for any purpose not listed in paragraph 1 of Article 4 and paragraph 2 of Article 22 shall be permissible only with the prior consent of the Federal Republic of Germany. This shall apply in particular to the use of such data as evidence before a court dealing with general criminal matters that are not purely tax-related. To this extent the procedures for mutual judicial assistance in criminal matters and, for Member States of the European Union, procedures regarding cross-border cooperation in criminal matters, shall remain unaffected.
The Federal Republic of Germany shall not consider itself obliged to transmit tax data if the use of such data would violate the Federal Republic of Germany’s public policy (ordre public) or essential interests within the meaning of paragraph 2 of Article 21 of the Convention.
Insofar as the data transmitted are disclosed in court proceedings or in a court decision, the receiving Party shall ensure that such disclosure will not lead to the imposition or exectution of the death penalty against persons whose data were transmitted or to the use of such data, without the consent of the transmitting Party, for other purposes not covered by the Convention.
2. The receiving agency shall document the receipt of the personal data transmitted. At the request of the competent authority of the Federal Republic of Germany, the receiving agency shall provide information on the use of the transmitted data, the results achieved thereby, and the consequences of the use of the data.
3. In the event that inaccurate data, or data which should not have been transmitted, have been transmitted, the receiving agency shall be obliged to correct or delete such data without delay following notification by the transmitting agency.
4. The receiving agency shall inform the person or company whose data were transmitted of the collection of such data in the Federal Republic of Germany. The persons or companies concerned need not be informed if and as long as, on balance, it is considered that the public interest in not informing them outweighs their right to be informed. Such persons or companies must be subsequently informed without delay if the reasons for not informing them no longer apply.
5. With reference to paragraph 3 of Article 4 of the Convention, it is pointed out that the persons or companies whose data are concerned shall, in their request, be informed by the competent German authority as to what data were transmitted, to which receiving agency, and for what purpose. The persons or companies concerned need not be informed if and as long as, on balance, it is considered that the public interest in not informing them outweighs their right to be informed. Such persons or companies must be subsequently informed without delay if the reasons for not informing them no longer apply.
6. The receiving agency shall bear liability in accordance with its domestic law in the event that any persons or companies suffer unlawful damage due to the erroneous use of data transmitted as part of the exchange of data pursuant to this Convention.
7. Where German law provides for specific deadlines for deleting the transmitted data or deadlines for reviewing whether such data should be deleted, the transmitting agency of the Federal Republic of Germany shall inform the receiving agency accordingly. The receiving agency shall ensure compliance with such deadlines. In any case, the transmitted data shall be deleted as soon as they are no longer required for the purpose for which they were transmitted.
8. The receiving agency shall be obliged to take effective measures to protect the transmitted data against unauthorised access, unauthorised alteration and unauthorised disclosure.
9. In accordance with the third sentence of paragraph 2 of Article 22 of the Convention, the persons and authorities referred to in the first sentence of paragraph 2 may, notwithstanding the provisions of paragraph 1, disclose information in public court proceedings or in judicial decisions relating to taxes in question.
The Governement of the Federal Republic of Germany interprets the third sentence of paragraph 2 of Article 22 to mean that, the disclosure of such information in public court proceedings or in judicial decisions also includes disclosure in preliminary investigation by a public prosecutor.
Under German Law, confidentiality cannot be guaranteed in all preliminary investigations by public prosecutors, because in Germany the principle of confidentiality may be overridden with reference to the right of access to information not only in court proceedings but also in preliminary criminal investigations.
Annex A – Taxes to which the Convention would apply
Preliminary note: Taxes imposed on behalf of the Länder have been classified as taxes imposed on behalf of a Contracting State.
Article 2, paragraph 1.a.i:
Income tax (including wages tax (Lohnsteuer), withholding tax on income from capital (Kapitalertragsteuer), interest income deduction (Zinsabschlag), withholding tax for construction work (Steuerabzug bei Bauleistungen), and special forms of levying income tax in accordance with section 50a of the Income Tax Act).
Corporation tax (Körperschaftsteuer).
Solidarity surcharge (Solidaritätszuschlag).
Ancillary tax payments.
Article 2, paragraph 1.a.ii:
Article 2, paragraph 1.a.iii:
Net worth tax (Vermögensteuer).
Ancillary tax payments.
Article 2, paragraph 1.b.i:
Trade tax (Gewerbsteuer).
Ancillary tax payments.
Article 2, paragraph 1.b.ii:
Contribution to statutory health, long-term care, accident and pension insurance, including pension insurance for farmers and employment promotion.
Article 2, paragraph 1.b.iii.A:
Inheritance tax (Erbschaftsteuer).
Gift tax (Schenkungsteuer).
Substitute inheritance tax (Ersatzerbschaftsteuer).
Ancillary tax payments.
Article 2, paragraph 1.b.iii.B:
Real property tax (Grundsteuer).
Real property tax transfer (Grunderwerbsteuer).
Ancillary tax payments.
Article 2, paragraph 1.b.iii.C:
Import VAT (Einfuhrumsatzsteuer).
Value added tax (Umsatzsteuer).
Ancillary tax payments.
Article 2, paragraph 1.b.iii.D:
Spirits duty (Branntweinsteuer).
Energy duty (Energiesteuer).
Tobacco duty (Tabaksteuer).
Ancillary tax payments.
Article 2, paragraph 1.b.iii.E:
Article 2, paragraph 1.b.iii.F:
Article 2, paragraph 1.b.iii.G:
Aviation tax (Luftverkehrsteuer).
Betting and lottery tax (Rennwett- und Lotteriesteuer).
Taxe on insurance premiums.
Ancillary tax payments.
Article 2, paragraph 1.b.iv:
Real property tax (Grundsteuer).
Ancillary tax payments.
Annex B – Competent Authorities
1. For taxes and related ancillary tax payments, with the exception of the taxes and ancillary tax payments listed in paragraph 3 below:
The Federal Ministry of Fincance or the authority (the Federal Central Tax Office) to which it has delegated its powers;
2. For all social security contributions:
The Federal Ministry of Labour and Social Affairs;
3. For:
- Import VAT and related ancillary tax payments in accordance with Article 2, paragraph 1.b.iii.C,
- Spirits duty, energy duty, tobacco duty and related ancillary tax payments in accordance with Article 2, paragraph 1.b.iii.D,
- Aviation tax and related ancillary tax payments in accordance with Article 2, paragraph 1.b.iii.G,
The Customs Criminological Office, to which the Federal Ministry of Finance has delegated its powers;
4. For the service of documents in accordance with Article 17 which relate to taxes and ancillary tax payments listed in paragraph 3 above:
The Federal Office for Customs Enforcement (at the Hanover main customs office), to which the Federal Ministry of Finance has delegated its powers.
Annex C – Definition of the word "national" for the purpose of the Convention
- All Germans within the meaning of the Basic Law for the Federal Republic of Germany, and
- All legal persons, partnerships and other associations deriving their status as such from the laws in force in the Federal Republic of Germany.

24-02-2017

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 Federal Republic of Germany 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, the Federal Republic of Germany 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;
The Federal Republic of Germany 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 Federal Republic of Germany 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 Federal Republic of Germany declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between the Federal Republic of Germany 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.

24-02-2017

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.
Considering that the Federal Republic of Germany intends to start automatically exchanging CbC Reports as of 2018 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”), the Federal Republic of Germany has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 27 January 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 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 Federal Republic of Germany declares that the amended Convention shall have effect in accordance with the terms of the CbC MCAA for administrative assistance under the CbC MCAA between the Federal Republic of Germany 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.

Ghana

29-05-2013

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
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

Greece

29-05-2013

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.
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.
Annex C - Definition of the term "national" for the purpose of the Convention
None provided.
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.

14-12-2017

05-03-2018

Grenada

31-05-2018

Annex A - Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i:
. Personal Income Tax,
. Corporate Income Tax,
. Withholding Tax.
Article 2, paragraph 1.a.ii: None.
Article 2, paragraph 1.a.iii: None.
Article 2, paragraph 1.b.i: None.
Article 2, paragraph 1.b.ii: National Insurance Scheme Contribution.
Article 2, paragraph 1.b.iii.A: Inheritance Tax.
Article 2, paragraph 1.b.iii.B:
. Property Tax,
. Property Transfer Tax.
Article 2, paragraph 1.b.iii.C:
. Value Added Tax,
. Annual Stamp Tax.
Article 2, paragraph 1.b.iii.D: Inland Revenue Excise Tax.
Article 2, paragraph 1.b.iii.E: None.
Article 2, paragraph 1.b.iii.F: None.
Article 2, paragraph 1.b.iii.G: Gaming Tax.
Annex B - Competent authorities:
The Comptroller of Inland Revenue Division.

Guatemala

09-06-2017

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.

Hungary

07-11-2014

Pursuant to Article 30, paragraph 1.c, of the Convention, Hungary 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 Hungary.
Annex A - Existing taxes to which the Convention would apply
Article 2, paragraph 1.a:
i) personal income tax, corporate income tax.
Article 2, paragraph 1.b:
i) land parcel tax, building tax, local business tax,
ii) social contribution tax and contributions (pension contribution, health insurance contribution, labour market contribution),
iii) A: duties (inheritance tax, duty on gifts, duty on onerous transfer of property),
C. value added tax,
D. excise duties.
iv) motor vehicle tax
Annex B - Competent Authorities
The Minister responsible for tax policy or his autorised representative.

28-03-2018

Iceland

22-07-1996

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.

28-10-2011

In accordance with Article 2, paragraph 3, of the Convention, Iceland declares that Annex A to the Convention has been changed as follows:
Annex A - Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i:
- the income tax to the state (tekjuskattar ríkissjóðs),
- the special tax on petroleum income (sérstakur skattur á kolvetnisvinnslu),
Article 2, paragraph 1.a.ii:
- -
Article 2, paragraph 1.a.iii:
- the net wealth tax (auðlegðarskattur),
Article 2, paragraph 1.b.i:
- the income tax to the municipalities (útsvar til sveitarfélaganna),
Article 2, paragraph 1.b.ii:
- social security tax (tryggingagjald),
- contribution to the construction fund for the elderly (gjald í framkvæmdasjóð aldraðra),
Article 2, paragraph 1.b.iii:
A. inheritance tax (erfðafjárskattur),
B. - -
C. value added tax (virðisaukaskattur),
D. excise duties on: (vörugjöld):
- carbondioxide charge on mineral oils and petrol (kolefnisgjald),
- national broadcasting charge (útvarpsgjald),
E. annual tax on motor vehicles (bifreiðagjald),
special charge on heavy vehicles (kílómetragjald),
F. market charge (markaðsgjald),
G. stamp duty (stimpilgjald),
charge on ship (skipagjöld),
lighthouse charge (vitagjald),
Article 2, paragraph 1.b.iv:
- municipal property tax (fasteignagjöld),
- planning charge (skipulagsgjald).
The Convention will continue to apply to taxes which have been repealed as long as the taxes remain enforceable and collectible, for taxes prior to the repeal until the statute of limitation has elapsed.

24-10-2014

Annex B - Competent Authorities
The Minister of Finance and Economic Affairs or the Minister's authorised representative.

12-12-2018

India

21-02-2012

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.
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.

06-04-2017

18-12-2017

Indonesia

21-01-2015

In accordance to Article 30, paragraph 1.a, of the Convention, the Republic of Indonesia 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. A, D, E, F, G and b.iv of Article 2, paragraph 1, of the Convention.
In accordance to Article 30, paragraph 1.b, of the Convention, the Republic of Indonesia 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 Articles 11 through 16 of the Convention.
In accordance to Article 30, paragraph 1.d, of the Convention, the Republic of Indonesia reserves the right not to provide assistance in the service of documents for the taxes listed in sub-paragraphs b.i, b.ii, b.iii. A, D, E, F, G and b.iv of Article 2, paragraph 1, of the Convention.
Annex A – Taxes to which the Convention would apply
Article 2, paragraph 1.a.i
Income Tax (including capital gains and net wealth that are subject to Income Tax at a rate determined under the Indonesian tax laws).
Article 2, paragraph 1b.iii. B
Land and Building Tax (plantation, forestry and mining sectors)
Article 2, paragraph 1b.iii. C
Value Added Tax and Sales Tax on Luxury Goods.
Annex B – Competent Authorities
The Republic of Indonesia declares that the term “competent authorities” means the Minister of Finance of Indonesia or an authorised representative of the Minister.

29-05-2018

24-09-2018

30-07-2024

Pursuant to Article 30, paragraph 4, of the Convention on Mutual Administrative Assistance in Tax Matters, the Government of the Republic of Indonesia partly withdraws its reservation as follows:
In accordance to Article 30, paragraph 1.b, of the Convention, the Republic of Indonesia 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 Articles 11 through 16 of the Convention, for the taxes listed in sub-paragraphs b.i, b.ii, b.iii, A, D, E, F, G, and b.iv of Article 2, paragraph 1, of the Convention.

The partial withdrawal of the reservation took effect as from 30 July 2024.

Ireland

29-05-2013

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.
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
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.
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.
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.

22-12-2017

Israel

31-08-2016

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.
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.

Italy

31-01-2006

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 taxes other 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.
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.
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 società - 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 attività produttive - IRAP).
Article 2, paragraph 1.b.iii
Under category C:
- Value Added Tax (Imposta sul valore aggiunto - IVA).
Annex B - Competent Authorities
The Ministry of Economy and Finance - Tax Policy Department.

18-03-2013

Pursuant to Article 2, paragraph 3 and 4, of the Convention, Italy makes the following amendments to Annex A:
Annex A - Taxes to which the Convention would apply:
Article 2, paragraph 1.b.iii
Under category G:
- Registration Tax (Imposta di registro);
- Mortgage and Cadastral Taxes (Imposte ipotecaria e catastale);
- Financial Transaction Tax (Imposta sulle Transazioni Finanziarie);
- Wealth tax on real estate located abroad (Imposta sul valore degli immobili situati all'estero);
- Wealth tax on financial assets held abroad (Imposta sul valore delle attività finanziarie detenute all'estero).
Article 2, paragraph 1 (b) (iv):
Local Property Tax (Imposta municipale propria - IMU).

05-01-2017

05-04-2017

18-07-2019

Date of effect of the declaration: 1 November 2019.

(consolidated version of declarations from 2006, 2013 and 2019)

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 taxes other 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.
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.
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 società - IRES and the former Imposta sul reddito delle persone giuridiche - IRPEG).
- Regional Tax on Productive Activities (Imposta regionale sulle attività produttive - IRAP).
Article 2, paragraph 1.a.ii
- Substitute Income Taxes, irrespective of their denomination
Article 2, paragraph 1.a.iii:
- Wealth tax on real estate located abroad (Imposta sul valore degli immobili situati all'estero - IVIE);
- Wealth tax on financial assets held abroad (Imposta sul valore delle attività finanziarie detenute all'estero - IVAFE).
Article 2, paragraph 1.b.i
[…]
Article 2, paragraph 1.b.iii.A:
- Inheritance tax (Imposta sulle successioni);
- Gift tax (Imposta sulle donazioni).
Article 2, paragraph 1.b.iii.C:
- Value Added Tax (Imposta sul valore aggiunto - IVA).
Article 2, paragraph 1.b.iii.G:
- Registration Tax (Imposta di registro);
- Mortgage and Cadastral Taxes (Imposte ipotecaria e catastale);
- Financial Transaction Tax (Imposta sulle Transazioni Finanziarie);
-[…]
Article 2, paragraph 1 (b) (iv):
- Local Property Tax (Imposta municipale propria - IMU).
Annex B - Competent Authorities
The Ministry of Economy and Finance - Tax Policy Department.

Jamaica

29-11-2018

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.

Japan

27-06-2013

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.
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
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.
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.

31-07-2014

Pursuant to Article 2, paragraph 4, of the Convention as amended, the Government of Japan notifies to the Secretary General of the OECD the adoption of the "local corporation tax" under the Local Corporation Tax Act (Law No. 11 of 2014) of Japan.
"The local corporation tax" is a national tax on income or profit and the tax base is the amount of "the corporation tax" listed in Annex A (sub-paragraph (a)(i)). Therefore, "the local corporation tax" is a substantially similar tax which is imposed in Japan in addition to "the corporation tax" within the meaning of paragraph 4 of Article 2 of the Convention. Since the Local Corporation Tax Act is to be enacted on 1 October 2014, the Convention shall apply to "the local corporation tax" from the same date.

02-08-2017

07-01-2021

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.

Jordan

11-08-2021

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.
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.

Objection Austria, 31-05-2022

The Government of Austria has carefully examined the declaration made by the Hashemite Kingdom of Jordan upon ratification of the Convention on mutual administrative assistance in tax matters as amended by the 2010 Protocol on 11 August 2021. Austria considers the declaration to amount to a reservation, because it aims at generally excluding the application of the Convention by Jordan on a unilateral basis in relation to any other State Party Jordan has or might in the future have no diplomatic relations with. This reservation is impermissible according to Article 30 of the Convention that prohibits reservations to this Convention except for those specifically mentioned, which do not include the reservation in question. Furthermore, the reservation is of an indeterminate scope since it is the prerogative of each state to determine the states it has diplomatic relations with, and diplomatic relations can be severed unilaterally at any time without specific reasons. The reservation is also contrary to the functioning of a multilateral treaty framework in general which, unless specifically provided for in the respective treaty, does not allow for the unilateral exclusion of a state that intends to become or is a State Party by another state that intends to become or is a State Party from the application of multilateral treaty obligations. Austria therefore considers the reservation to be contrary to the provisions and the object and purpose of the Convention and objects to it. This objection shall not preclude the entry into force of the Convention between the Republic of Austria and the Hashemite Kingdom of Jordan.

Kazakhstan

08-04-2015

In accordance to Article 30, paragraph 1.a, of the Convention, the Republic of Kazakhstan reserves the right not to provide any form of assistance in relation to the taxes of other Parties listed in Article 2, paragraph 1.b, of the Convention, except for taxes and other obligatory payments to the budget provided under Annex A of the Convention.
In accordance to Article 30, paragraph 1.b, of the Convention, the Republic of Kazakhstan 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, the Convention.
In accordance to Article 30, paragraph 1.c, of the Convention, the Republic of Kazakhstan 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 to the republic of Kazakhstan or at the date of withdrawal of such a reservation by the Republic of Kazakhstan in accordance with Article 30, paragraph 1. a or b, of the Convention.
Annex A – Taxes to which the Convention would apply
Article 2, paragraph 1.a.i
Corporate Income tax;
Personal income tax;
Social tax;
Article 2, paragraph 1.b.ii
Social contributions;
Mandatory pension contributions ;
Mandatory professional contributions.
Article 2, paragraph 1.b.iii. A
Property tax
Article 2, paragraph 1.b.iii. B
Land 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 transport vehicles ;
Article 2, paragraph 1.b.iii. G
Export rent tax;
Tax on gambling business;
Special payments and taxes for subsurface users;
Other obligatory payments to the budget.
Annex B – Competent Authorities
The Minister of Finance or its authorised representative.
Annex C – Definition of the word "national" for the purpose of the Convention
- All individuals possessing the nationality of the Republic of Kazakhstan;
- All legal persons, partnerships or association deriving its status as such from the laws in force in the Republic of Kazakhstan.

Kenya

22-07-2020

The Republic of Kenya ratifies the Convention with the following declarations:
ANNEX A – Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i: Income Tax.
Article 2, paragraph 1.a.ii: Capital Gains Tax.
Article 2, paragraph 1.b.ii: National Social Security Fund contributions.
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: Advance Tax.
ANNEX B – Competent Authorities
The Cabinet Secretary responsible for Finance or his authorised representative.

Kuwait

17-08-2018

Annex A – Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i: Corporate income tax
Article 2, paragraph 1.a.ii: Income tax as per Law No. 23 of 1961
Article 2, paragraph 1.a.iii: Tax subjected according to the Supporting of National Employees Law
Annex B – Competent Authorities
The Minister of Finance or his authorised representative.

30-10-2018

Latvia

15-07-2014

In accordance with Article 30, paragraph 1.a, of the Convention, the Republic of Latvia reserves the right not to provide any form of assistance in relation to the following taxes of other Parties that are listed in Article 2, paragraph 1.b:
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;
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 referred to in Article 2, paragraph 1.b.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 Latvia 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 to which the above reservation applies.
In accordance with Article 30, paragraph 1.c, of the Convention, the Republic of Latvia 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 Latvia or, where a reservation has been made under sub-paragraph a or b, till 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 Latvia reserves the right not to provide assistance in the service of documents for taxes covered by the above reservation regarding Article 30, paragraph 1.a.
In accordance with Article 30, paragraph 1.f, of the Convention, the Republic of Latvia 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 Latvia, 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 Latvia.
Annex A - Existing taxes to which the Convention shall apply
Article 2, paragraph 1.a.i:
- Income tax;
- Corporation tax ;
Article 2, paragraph 1.b.iii:
B. Taxes on immovable property;
C. Value-Added Tax;
D. Excise taxes.
Annex B - Competent Authorities
The Ministry of Finance or its authorised representative.
In accordance with Article 4, paragraph 3, of the Convention, the Republic of Latvia declares that according to its initial legislation its authorities may inform its resident or national before transmitting information concerning him, in conformity with Article 5 and 7.

Lebanon

12-05-2017

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 sub-paragraph 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 authorised representative.

12-05-2017

Liberia

29-08-2018

Annex B – Competent Authorities
The Liberia Revenue Authority

26-08-2021

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.

21-10-2022

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.
Considering that Liberia intends to start automatically exchanging Country by Country Reports as of 2018 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”), Liberia has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 1 June 2022;
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;
Liberia declares that the amended Convention shall have effect in accordance with the terms of the CbC MCAA for administrative assistance under the CbC MCAA between Liberia 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.

Liechtenstein

17-10-2014

Declaration of competent authorities of Liechtenstein:
Annex B - Competent authorities
The Government of the Principality of Liechtenstein or its authorised representative.
The Office for Foreign Affairs wishes to point out that the Principality of Liechtenstein reserves the right to confirm or supplement this notification and to make reservations in accordance with Article 30 of the Convention when depositing its instrument of ratification of the Convention or at any later stage.

22-08-2016

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 (Grundstücksgewinnsteuer)
Article 2, paragraph1.a (iii):
- Wealth Tax (Vermögenssteuer)
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.

15-09-2017

Lithuania

15-05-2014

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.

22-10-2014

Updated list of the competent authorities of the Republic of Lithuania:
Annex B - Competent authorities
In relation to the Republic of Lithuania, the term "competent authority" means the Ministry of Finance or the State Tax Inspectorate under the Ministry of Finance.

15-12-2017

18-04-2018

Luxembourg

11-07-2014

In accordance with Article 30, paragraph 1.a, of the Convention, the Grand Duchy of Luxembourg does not provide any form of assistance in relation to the taxes of other Parties in any of the categories listed in Article 2, paragraph 1.b,of the Convention.
In accordance with Article 30, paragraph 1.b, of the Convention, the Grand Duchy of Luxembourg does not provide assistance in the recovery of any tax claim or in the recovery of an administrative fine, except for taxes of other Parties in one of the categories listed in Article 2, paragraph 1.a, of the Convention.
In accordance with Article 30, paragraph 1.c, of the Convention, the Grand Duchy of Luxembourg does 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 Grand-Duchy of Luxembourg.
In accordance with Article 30, paragraph 1.d, of the Convention, the Grand Duchy of Luxembourg does not provide assistance in the service of documents except for taxes of other Parties in one of the categories listed in Article 2, paragraph 1.a, of the Convention.
In accordance with Article 30, paragraph 1.f, of the Convention, the Grand Duchy of Luxembourg declares that, with respect to tax matters involving intentional conduct which is liable to prosecution under the criminal laws of the requesting Party, the provisions of the Convention 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 entered into force for the Grand Duchy of Luxembourg, 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 for the Grand Duchy of Luxembourg.
Annex A - Existing taxes to which the Convention shall apply
Article 2, paragraph 1.a.i - taxes on income or profits
- tax on personal income;
- tax on communities income;
- wealth tax;
- municipal business tax;
Article 2, paragraph a.ii - taxes on capital gains which are imposed separately from the tax on income or profits
None.
Article 2, paragraph a.iii - tax on net wealth
None.
Annex B - Competent Authorities
The Minister of Finance or his authorised representative.

31-03-2017

30-08-2017

Malaysia

25-08-2016

03-01-2017

Pursuant to Article 30, paragraph 1.a, of the Convention, Malaysia reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in the categories listed in sub-paragraph b of paragraph 1 of Article 2, of the Convention.
In accordance with Article 30, paragraph 1.b, of the Convention, Malaysia 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, Malaysia reserves the right not to provide assistance in the service of documents for all taxes.
Annex A - Taxes to which the Convention would apply
Article 2, paragraph 1.a.i:
Income Tax
Petroleum income tax
Article 2, paragraph 1.a.ii :
Real property gain tax.
Annex B - Competent authorities
In relation to Malaysia, the term “competent authority” means the Minister of Finance or his authorised representative.
Annex C - Definition of the word "national" for the purpose of the Convention
In relation to Malaysia, the term “national” means:
(i) any individual possessing the nationality or citizenship of Malaysia;
(ii) Any legal person, partnership or, association and any other entity deriving its status as such from the laws in force in Malaysia.

31-05-2017

Maldives

11-08-2021

Maldives sign the Convention […] with the following notification:
ANNEX B – Competent Authorities
The Commissioner General of Taxation or their authorised representative.

20-09-2021

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.

10-01-2022

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.
Considering that Maldives intends to start automatically exchanging Country by Country Reports as of 2023 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”), Maldives has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 12 August 2021;
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;
Maldives declares that the amended Convention shall have effect in accordance with the terms of the CbC MCAA for administrative assistance under the CbC MCAA between Maldives 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.

10-01-2022

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.
Considering that Maldives has committed to automatically exchange information as of 2022 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, Maldives has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 12 August 2021;
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;
Maldives 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 Maldives 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.
Maldives declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between Maldives 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.

Malta

29-05-2013

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

06-09-2017

Considering that Malta intends to start automatically exchanging CbC Reports as of 2018 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”), Malta has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by- Country reports (hereafter the “CbC MCAA”) on 26 January 2017;
...
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

06-04-2018

Marshall Islands

22-12-2016

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.

22-12-2016

Mauritania

12-02-2019

In accordance with Article 30, paragraph 1.a, of the Convention, the Islamic Republic of Mauritania 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;
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,
D. specific taxes on goods and services such as excise taxes,
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 Islamic Republic of Mauritania 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 Islamic Republic of Mauritania 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 Islamic Republic of Mauritania 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 Islamic Republic of Mauritania, 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 Islamic Republic of Mauritania.
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 in charge of Finance or its 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.

29-04-2022

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.

Mauritius

23-06-2015

Annex B – Competent Authorities
The Director General of the Mauritius Revenue Authority or his authorized representative.

31-08-2015

Annex A – Taxes to which the Convention would apply
Article 2, paragraph 1.a.i
- taxes on income or profits.
Article 2, paragraph 1.b.iii.C
- general consumption taxes, such as value added or sales taxes.
Article 2, paragraph 1.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 – Competent Authorities
The Minister to whom the responsibility for the subject of finance is assigned or his authorised representative.
Annex C – Definition of the word "national" for the purpose of the Convention
(i) all individuals possessing the citizenship of the Republic of Mauritius, and
(ii) all legal persons, partnerships, associations and other entities deriving their status as such from the laws in force in the republic of Mauritius.

23-03-2017

Mexico

23-05-2012

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 subparagraph 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.
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
Annex B - Competent Authorities
- Ministry of Finance;
- Tax Administration Service.
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.

11-01-2017

Moldova

24-11-2011

Annex A - Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i: taxes on income of individuals and legal entities;
Article 2, paragraph 1.b.ii: social security contributions;
Article 2, paragraph 1.b.iii.B: taxes on immovable property;
Article 2, paragraph 1.b.iii.C: value-added taxes;
Article 2, paragraph 1.b.iii.D: excise taxes;
Article 2, paragraph 1.b.iii.E: taxes on the use of motor vehicles;
Article 2, paragraph 1.b.iv: taxes on natural resources; local taxes;
Annex B - Competent authorities:
The Ministry of Finance or its authorized representatives.
Based on Article 29, paragraph 1, of the Convention, Moldova declares that, until the full re-establishment of the territorial integrity of the Republic of Moldova, the provisions of the Convention will be applied only on the territory controlled effectively by the Republic of Moldova's authorities.

07-03-2019

Annex B - Competent authorities
The Ministry of Finance or its authorised representatives;
1. Mihai Burunciuc - Head of the International cooperation and information exchange Division. Cooperation and information exchange Department.
State Tax Service.
Contact details: MD-2005, Chişinău mun., 9 Constantin Tănase str.;
Tel. +373 22 823368;
E-mail: mihai.burunciuc@sfs.md;
2. Silvia Caitaz - Main inspector, International cooperation and information exchange Division. Cooperation and information exchange Department.
State fax Service.
Contact details: MD-2005. Chişinău mun., 9 Constantin Tănase str.;
Tel. +373 22 823368;
E-mail: silvia.caitaz@sfs.md.
3. Victoria Bolea - Inspector, International cooperation and information exchange Division, Cooperation and information exchange Department.
State Tax Service.
Contact details: MD-2005, Chişinău mun.. 9 Constantin Tănase str.;
Tel. +373 22 823368;
E-mail: victoria. bolea@sfs.md.

Monaco

18-12-2015

Annex B – Competent Authorities
The term "competent authority" means in the case of the Principality of Monaco, the Government Minister for Finance and the Economy (“Conseiller de Gouvernement pour les Finances et l’Economie”) or his authorised representative.

14-12-2016

In accordance with Article 30, paragraph 1.a, of the Convention, the Principality of Monaco does not provide any form of assistance in relation to the taxes of other Parties in any of the categories listed in Article 2, paragraph 1.b, of the Convention.
In accordance with Article 30, paragraph 1.b, of the Convention, the Principality of Monaco does not provide assistance in the recovery of any tax claim, 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 Monaco 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 the Principality or at the date of withdrawal of a reservation, made under sub-paragraph a or b, in relation to taxes in the category in question.
In accordance with Article 30, paragraph 1.d, of the Convention, the Principality of Monaco does not provide any assistance in the service of documents, for all taxes under Article 2, paragraph 1, of the Convention.
In accordance with Article 30, paragraph 1.e, of the Convention, the Principality of Monaco does not accept the service of documents through the post as provided for in Article 17, paragraph 3, of the Convention.
In accordance with Article 30, paragraph 1.f, of the Convention, the Principality of Monaco 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 entered into force in respect of the Principality, 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 the Principality.
Declarations
In accordance with Article 4, paragraph 3, of the Convention, the competent authority of the Principality of Monaco may inform the persons concerned, namely its residents and its nationals, before providing information concerning them to another Party, in conformity with Monegasque law.
In accordance with Article 9, paragraph 3, of the Convention, the competent authority of the Principality of Monaco reserves the right not to accept, as a general rule, requests from the competent authority of the applicant State to be present at the appropriate part of a tax examination in the requested State, namely in the Principality of Monaco.
Notifications
Annex A - Taxes to which the Convention would apply
Article 2, paragraph 1.a.i
• Tax on profits of industrial and commercial incomes of individuals;
• Corporate profits tax.
Annex B - Competent authorities
The Government Adviser - Minister of Finance and Economy or his authorised representative.

Mongolia

19-02-2020

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

28-01-2020

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.

Morocco

22-05-2019

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.
Annex A - Taxes to which the Convention would apply
Article 2, paragraph 1.a.i:
Income Tax, and
Corporation Tax.
Annex B - Competent authorities
For Morocco, the term “competent authorities” designates the Minister for Economy and Finances or his authorised representative.

Namibia

09-12-2020

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

28-06-2016

Annex A - Existing taxes to which the Convention shall apply:
Article 2, paragraph 1.a.i:
- Employment and Services Tax
- Business Tax (Including: Business Profit Tax, Small Business Tax, Non Resident Tax and International Transportation Business Tax)
Article 2, paragraph 1.b.iii.D:
-Telecommunication Services Tax
Article 2, paragraph 1.b.iii.E:
- Motor Vehicle Tax
Article 2, paragraph 1.b.iii.G:
- Fisheries Tax
- Nauru Phosphate Royalty Levy/Tax
- Civil Aviation Fees/Tax
Annex B - Competent authority:
The Minister of Finance or his authorised representative.

15-02-2017

Netherlands, the Kingdom of the

29-05-2013

The Kingdom of the Netherlands (for Curaçao) declares, in accordance with Article 30, paragraph 1 (a), (b), (c), (d) and (e) of the Convention, that it reserves the right:
- not to provide assistance in relation to compulsory social security contributions payable to general government or to social security institutions established under public law, as referred to in article 2, paragraph 1 (b) (ii) of the Convention.
The Kingdom of the Netherlands (for Sint Maarten) declares, in accordance with Article 30, paragraph 1 (a), (b), (c), (d) and (e) of the Convention, that it reserves the right:
- not to provide assistance in relation to compulsory social security contributions payable to general government or to social security institutions established under public law, as referred to in article 2, paragraph 1 (b) (ii) of the Convention; and
- not to provide assistance in relation to the taxes referred to in article 2, paragraph 1 (b) (iii) (B) and (D) of the Convention.
The Kingdom of the Netherlands (for Aruba, Curaçao and Sint Maarten) declares that the reservation referred to in Article 30, paragraph 1 (f) of the Convention of 25 January 1988, is made that retroactive effect in respect of Aruba, Curaçao and Sint Maarten is limited to three years prior to the entry into force of the Protocol of 27 May 2010.
For the European part of the Netherlands:
The Kingdom of the Netherlands (for the European part of 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 of the Convention.
For the Caribbean part of the Netherlands (the islands of Bonaire, Sint Eustatius and Saba):
The Kingdom of the Netherlands (for the Caribbean part of 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 of the Convention.
For Aruba:
The Kingdom of the Netherlands (for Aruba) 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 of the Convention.
For Curaçao:
The Kingdom of the Netherlands (for Curaçao) 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 of the Convention.
The Kingdom of the Netherlands (for Curaçao) 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, in so far as the requests concern social security contributions.
For Sint Maarten:
The Kingdom of the Netherlands (for Sint Maarten) 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 of the Convention.
The Kingdom of the Netherlands (for Sint Maarten) 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, in so far as the requests concern social security contributions, taxes on immovable property and specific taxes on goods and services such as excise taxes.
Annex A
Taxes to which the Convention applies for the European part of the Netherlands:
Article 2, paragraph 1 (a) (i)
- Income tax (Inkomstenbelasting)
- Salaries tax (Loonbelasting)
- Corporation tax (Vennootschapsbelasting)
- Dividend tax (Dividendbelasting)
Article 2, paragraph 1 (b) (ii)
- Social security contributions (Premies sociale verzekering)
Article 2, paragraph 1 (b) (iii)
A. Inheritance, Transfer or Gift Tax (erfbelasting, schenkbelasting)
C. Value added tax (Omzetbelasting)
Taxes to which the Convention applies for the Caribbean part of Netherlands (the islands of Bonaire, Sint Eustatius and Saba):
Article 2, paragraph 1 (a) (i)
- Income tax (Inkomstenbelasting)
- Salaries tax (Loonbelasting)
- Corporation tax (Vennootschapsbelasting)
Taxes to which the Convention applies for Aruba:
Article 2, paragraph 1 (a) (i)
- Income tax (Inkomstenbelasting)
- Salaries tax (Loonbelasting)
- Corporation tax (Winstbelasting)
- Dividend tax (Dividendbelasting)
Taxes to which the Convention applies for Curaçao:
Article 2, paragraph 1 (a) (i)
- Income tax (Inkomstenbelasting)
- Salaries tax (Loonbelasting)
- Corporation tax (Winstbelasting)
Article 2, paragraph 1 (b) (iii)
A. Inheritance tax (Successiebelasting)
B. Land tax (Grondbelasting)
C. Value added tax (Omzetbelasting)
D. Excise duties (Accijnzen):
- special import duty on petrol (bijzonder invoerrecht op benzine)
- excise duty on beer (accijns op bier)
- excise duty on cigarettes (accijns op sigaretten)
- excise duty on spirits (accijns op gedistilleerd)
E. Motor vehicles tax (Motorrijtuigenbelasting)
Taxes to which the Convention applies for Sint Maarten:
Article 2, paragraph 1 (a) (i)
- Income tax (Inkomstenbelasting)
- Wage tax (Loonbelasting)
- Profit tax (Winstbelasting)
- Savings tax (Spaarvermogensheffing)
Article 2, paragraph 1 (b) (iii)
A. Inheritance tax (Successiebelasting)
B. Transfer tax (Overdrachtsbelasting)
C. Turnover tax (Belasting op bedrijfsomzetten)
E. Motor vehicles tax (Motorrijtuigenbelasting)
Annex B
Competent Authorities for the European part of 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
Competent Authorities for the Caribbean part of the Netherlands (the islands of Bonaire, Sint Eustatius and Saba):
The Minister of Finance or his authorised representative
Competent Authorities for Aruba:
The Minister of Finance or his authorised representative
Competent Authorities for Curaçao:
The Minister of Finance or his authorised representative
Competent Authorities Sint Maarten:
The Minister of Finance or his authorised representative
Annex C
The term "national" means for the European part of the Netherlands, the Caribbean part of the Netherlands (the islands of Bonaire, Sint Eustatius and Saba), Aruba, Curaçao and Sint Maarten:
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 European part of the Netherlands, the Caribbean part of the Netherlands (the islands of Bonaire, Sint Eustatius and Saba), Aruba, Curaçao and Sint Maarten.

23-10-2014

The Kingdom of the Netherlands amends Annex A, for the European and Caribean part of the Netherlands, as follows:
Annex A - Taxes to which the Convention would apply
For the European part of the Netherlands, the Convention shall apply to taxes of every kind and description which fall whithin categories set out in Article 2.1.a and 2.1.b.
For the Caribean part of the Netherlands (the islands of Bonaire, Sint Eustatius and Saba), the Convention shall apply to taxes of every kind and description which fall within categories set out in Article 2.1.a and 2.1.b.

22-07-2016

20-12-2016

14-08-2018

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.
The Permanent Mission of the Kingdom of the Netherlands to the Council of Europe has the honor to refer to the underneath declaration for the Kingdom of the Netherlands, on behalf of Curaçao, 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 Curaçao 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”), Curaçao 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;
[...]
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

14-08-2018

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.
The Permanent Mission of the Kingdom of the Netherlands to the Council of Europe 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 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”), Aruba 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;
[...]
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

14-08-2018

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 Council of Europe has the honor to refer to the underneath declaration for the Kingdom of the Netherlands, on behalf of Curaçao, 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 Curaçao intends to start automatically exchanging Country-by-Country reports (hereafter the “CbC MCAA”) as of 2018 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”), Curaçao has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports on 30 June 2016;
[...]
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

05-08-2020

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 Co-operation 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;
[...]
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

New Zealand

21-11-2013

The Government of New Zealand declares that the ratification of the Convention shall not extend to Tokelau unless and until a Declaration to this effect is lodged by the Government of New Zealand with the depositary on the basis of appropriate consultation with that territory.
Annex A - Taxes to which the Convention would apply:
Taxes of every kind and description imposed under the laws of New Zealand administered by the Commissioner of Inland Revenue, which correspond to the taxes in the categories referred to in paragraphs 1(a) and (b)(iii) A, C, D, G of Article 2 of the Convention.
Annex B - Competent Authorities
The Commissioner of Inland Revenue or an authorised representative of the Commissioner.
Annex C - Definition of a "national" for the purpose of the Convention
Any individual possessing the nationality or citizenship of New Zealand and any legal person, partnership or association deriving its status as such from the laws in force in New Zealand.

04-01-2018

Nigeria

29-05-2015

Pursuant to Article 30, paragraph 1.a, of the Convention, the Federal Republic of Nigeria will not provide any form of assistance in relation to the taxes of other Parties included in the following categories of listed taxes 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 social security institutions established under public law;
iii. E. taxes on the use or ownership of 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 Federal Republic of Nigeria will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
Annex A – Taxes to which the Convention would apply
Article 2, paragraph 1.a.i
Personal Income Tax;
Company Income Tax;
Petroleum Profit Tax;
Article 2, paragraph 1.a.i
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. G
Tertiary Education Tax;
National Information Technology Development Levy.
Annex B – Competent Authorities
The Minister of Finance or an authorised representative of the Minister.
Annex C – Definition of the word "national" for the purpose of the Convention
Any individuals possessing the nationality of the Federal Republic of Nigeria and any legal person, partnership, association, or other entity deriving its status as such from the laws in force in the Federal Republic of Nigeria.

Niue

27-11-2015

Annex B - Competent authorities
In accordance with Article 3(1)(d) of the Convention, the competent authority for Niue is the Financial Secretary, Department of Finance and Planning.

06-06-2016

Annex A - Taxes to which the Convention applies
Article 2, paragraph 1.a.i:
Taxes on income or profits
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 1.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 – Competent Authorities
In relation to Niue, the term “competent authority” means the Financial Secretary of the Department of Finance and Planning or an authorised representative of the Financial Secretary.
Annex C - Definition of the word "national" for the purpose of the Convention
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.

North Macedonia

30-09-2019

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.
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 (Данок на личен доход);
. Corporate Income Tax (Данокнадобивка).
Article 2, paragraph 1.b.ii:
. Compulsory Social Security Contribution (Придонеси од задолжителено социјално осигурување).
Article 2, paragraph 1.b.iii.C:
. Value Added Tax (Данок на додадена вредност).
Article 2, paragraph 1.b.iii.D:
. Excise (Акцизи).
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.

Norway

13-06-1989

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 B
The Minister of Finance and Customs or his authorised representative.

29-02-2008

In application of Article 2, paragraph 2, of the Convention, Norway communicates a modified list of national taxes to be included in Annex A of the Convention:
Article 2, paragraph 1.a:
i) National tax on personal income (skatt på personinntekt)
National tax on ordinary income (skatt på alminnelig inntekt);
National equalization tax (fellesskatt);
Special tax on petroleum income (særlig skatt på petroleumsinntekt);
Resource rent tax on income from hydro-electric power (grunnrenteskatt på inntekt fra produksjon av vannkraft);
Withholding tax on dividends (kildeskatt på utbytter);
Tonnage tax (tonnasjeskatt);
National tax on remuneration to non-resident artists (skatt til staten på honorarer til utenlandske artistene mv. );
iii) National tax on capital (formuesskatt til staten).
Article 2, paragraph 1.b:
i) County municipal tax on ordinary income (skatt til fylkeskommunen på alminnelig inntekt);
Municipal tax on ordinary income (skatt til kommunen på alminnelig inntekt);
County municipal and municipal natural resource tax (naturressursskatt til fylkeskommune og kommune);
Municipal tax on capital (formuesskatt til kommunen);
ii) Employees' contributions to the National Insurance Scheme (folketrygdavgift);
Employers contributions to the National Insurance Scheme (arbeidsgiveravgift);
iii) A. - Tax on inheritance and certain gifts (avgift på arv og visse gaver);
B. - -
C. - Value-added tax (merverdiavgift);
Investment tax (investeringsavgift);
D. - Taxes and excises on :
Alcohol (alkohol), alcoholic beverages (brennevin og vin m.v. ) bee (øl) and alcohol in imported essences (alkohol i essenser som innføres);
Autodiesel (autodiesel);
Carbondioxide from mineral oils, petrol and gas (CO2 avgift på mineralolje, bensin og gass);
Sulphur (svovel);
Beverage packaging (drikkevareemballasje);
Final treatment of waste (sluttbehandling av avfall);
Tobacco (tobakksvarer);
Petrol (bensin);
Mineral oil, base tax on heating oil (fyringsolje);
Lubricants (smøreolje);
Marine engines (båtmotorer);
Electricity consumption (forbruk av elektrisk kraft);
Chocolates and sweets (sjokolade);
Sugar (sukker);
Non-alcoholic beverages (alkoholfrie drikkevarer);
Trichloreten and tetrachloreten (TRI og PER);
Hydrofluorocarbons (HFC) and perfluorocarbons (PFC) (HFK og PFK);
Emissions of NOx (utslipp av NOx);
E. - -
F. - -
G. - Annual tax on motor vehicles (årsavgift på motorvogner);
Tax on motor vehicles etc. (engangsavgift på motorvogner m.v. );
Re-registration tax (omregistreringsavgift);
Annual tax on heavy goods vehicles (årsavgift på tyngre kjøretøyer);
Tax on documents transferring title to real property (avgift på dokument som overfører hjemmel til fast eiendom).

25-01-2018

Oman

26-11-2019

The Sultanate of Oman signs the Convention with the following notification:
Annex B – Competent Authority
The Chairman of Tax Authority or his authorized representative.

07-07-2020

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.

07-07-2020

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 Sultanate of Oman has committed to automatically exchange information in 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 […] (hereafter the “amended Convention”) in accordance with the timeline to which it has committed, the Sultanate of Oman has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 26 November 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 Sultanate of Oman 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 Sultanate of Oman 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 Sultanate of Oman declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between the Sultanate of Oman 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.

Pakistan

14-12-2016

Pursuant to Article 30, paragraph 1.a, of the Convention, the Islamic Republic of Pakistan 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, of the Convention:
- Article 2, 1.b.ii
- Article 2, 1.b.iii. A, B, F and G
- Article 2, 1.b.iv
In accordance with Article 30, paragraph 1.b, of the Convention, the Islamic Republic of Pakistan reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine for taxes in the following categories:
- Article 2, 1.a.iii
- Article 2, 1.b.ii
- Article 2, 1.b.iii.A, B, F and G
- Article 2, 1.b.iv
In accordance with Article 30, paragraph 1.c, of the Convention, the Islamic Republic of Pakistan reserves the right not to provide assistance in respect any of tax claim which is in existence at the date of entry into force of the Convention in respect of Pakistan.
In accordance with Article 30, paragraph 1.d, of the Convention, the Islamic Republic of Pakistan reserves the right not to provide assistance in the service of documents in respect of the taxes in the following categories:
- Article 2, 1.a.iii
- Article 2, 1.b.ii
- Article 2, 1.b.iii.A, B, F and G
- Article 2, 1.b.iv
In accordance with Article 30, paragraph 1.e, of the Convention, the Islamic Republic of Pakistan reserves the right not to permit the service of documents through the post as provided for in Article 17, paragraph 3, of the Convention, in respect of the taxes in the following categories:
- Article 2, 1.a.iii
- Article 2, 1.b.ii
- Article 2, 1.b.iii.A, B, F and G
- Article 2, 1.b.iv
Annex A - Taxes to which the Convention would apply
Article 2, paragraph 1.a.i: Income Tax
Article 2, paragraph 1.b.iii.C : Sales Tax
Article 2, paragraph 1.b.iii.D : Federal Excise Duty
Annex B - Competent authorities
Competent authority means “Chairman Federal Board of Revenue” or its authorised representative.
Annex C - Definition of the word "national" for the purpose of the Convention
The term national means:
(i) Any individual possessing the nationality of Pakistan;
(ii) Any legal person, partnership, association or other entity deriving their status as such from the laws in force in Pakistan.

12-10-2017

31-01-2018

Panama

16-03-2017

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 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 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.

20-03-2018

Papua New Guinea

20-07-2023

31-08-2023

In accordance with Article 30, paragraph 1.a, of the Convention, Papua New Guinea 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 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;
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, Papua New Guinea 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, 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.e, of the Convention, Papua New Guinea 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, Papua New Guinea 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 Papua New Guinea, 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 Papua New Guinea.
The Independent State of Papua New Guinea 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;
. dividend withholding tax;
. interest withholding tax;
. foreign contractors withholding tax;
. royalty withholding tax;
. management fee withholding tax;
. non-resident insurer tax;
. overseas shipowner or charterer tax.
Article 2, paragraph 1.a.ii: Capital gains tax.
Article 2, paragraph 1.b.iii.G: Stamp tax duty.
ANNEX B – Competent Authorities
The Commissioner General of Internal Revenue or his authorized representative.

Paraguay

15-07-2021

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 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.
The Republic of Paraguay ratifies the Convention […] as amended by the Protocol […], 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.

Peru

28-05-2018

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 - ESSALUD
- Contributions to the national pension system - ONP
Article 2, paragraph 1.b.iii.C:
- Value Added Tax
Article 2, paragraph 1.b.iii.D:
- Selective Consumption Tax.
Article 2, paragraph 1.b.iii.E:
- Recreational Boat Tax
Article 2, paragraph 1.b.iii.G:
- Tax on Financial Transactions
- Temporary Tax on Net Assets
Annex B - Competent authorities:
The term “Competent Authority” means the National Superintendence of Customs and Tax Matters - SUNAT.
Annex C - Definition of the word "national" for the purpose of the Convention:
The term “nationals” means all natural persons who have Peruvian nationality and all legal entities, partnerships, associations and other entities constituted in accordance with the legislation of the Republic of Peru.
Pursuant to Article 9, paragraph 3, of the Convention, the Republic of Peru will not accept, as a general rule, requests referred to in Article 9, paragraph 1, of the Convention.
In accordance with Article 30, paragraph 1.a, of the Convention, the Republic of Peru reserves the right not to provide any form of assistance in relation to the taxes of the other Parties included in the following categories listed in Article 2.1.b, of the Convention, and not mentioned in Peru’s 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 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 Peru reserves the right not to provide any form of assistance in the recovery of any tax claim, or in the recovery of an administrative fine, in respect of any kind of taxes, pursuant to Articles 11 to 16 of the Convention.
In accordance with Article 30, paragraph 1.c, of the Convention, the Republic of Peru 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 Peru 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 in relation to taxes in the category in question.
In accordance with Article 30, paragraph 1.d, of the Convention, the Republic of Peru reserves the right not to provide assistance in the service of documents, in respect of any kind of taxes, pursuant to Article 17 of the Convention.
In accordance with Article 30, paragraph 1.e, of the Convention, the Republic of Peru reserves the right not to permit the service of documents through the post as provided for in Article 17, paragraph 3, of the Convention.

21-12-2018

Poland

25-06-1997

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".

06-06-2018

Portugal

17-11-2014

Pursuant to paragraph 1.a of Article 30 of the Convention, Portugal reserves the right not to provide any form of assistance in relation to the compulsory social security contributions indicated in sub-paragraph b(ii) of paragraph 1 of Article 2 of the Convention.
Pursuant to paragraph 1.b of Article 30 of the Convention, Portugal reserves the right not to provide assistance in the recovery of any tax claim or in the recovery of an administrative fine in relation to the compulsory social security contributions indicated in sub-paragraph b(ii) of paragraph 1 of Article 2 of the Convention.
Pursuant to paragraph 1.d of Article 30 of the Convention, Portugal reserves the right not to provide assistance in the service of documents in relation to the compulsory social security contributions indicated in sub-paragraph b(ii) of paragraph 1 of Article 2 of the Convention.
Annex A - Taxes to which the Convention would apply
i) Article 2, paragraph 1.a.i
- Personal income tax
- Corporate income tax
- State surtax on corporate income tax
ii) Article 2, paragraph 1.b.i
- Local surtax on corporate income tax
iii) Article 2, paragraph 1b.iii. A
- Stamp duty on gratuitous transfers
iv) Article 2, paragraph 1b.iii. B
- Municipal tax on real property
- Municipal tax on real estate transfer
v) Article 2, paragraph 1b.iii. C
- Value added tax
vi) Article 2, paragraph 1b.iii. D
- Excise taxes
vii) Article 2, paragraph 1b.iii. E
- Tax on the ownership of motor vehicles
Annex B - Competent Authorities
Portugal declares that the term "competent authorities", included in Annex B, means the Minister of Finance, the Director General of the Tax and Customs Authority or their authorised representatives.

14-03-2017

05-12-2018

Qatar

10-11-2017

Annex B - Competent authorities
The Director of the Tax Department of the Ministry of Finance.

17-09-2018

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.

17-09-2018

01-03-2019

Republic of Korea, the

26-03-2012

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.
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.
Annex B. Competent Authorities
The Minister of Strategy and Finance or his authorised representative.
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.

30-09-2016

24-10-2017

Romania

11-07-2014

Annex A - Existing taxes to which the Convention shall apply
Article 2, paragraph 1.a.i:
- taxes on income or profits ;
Article 2, paragraph 1.b.ii:
- compulsory social security contributions provided by the Fiscal Code, respectively:
. contributions to the national social security health fund,
. contributions to the unemployment social security budget
. contributions to the State social security budget;
Article 2, paragraph 1.b.iii:
C. value added tax;
D. excise duties.
Annex B - Competent Authorities
The Minister of Public Finance or his autorised representative.
Annex C - Definition of the word "national" for the purposes of the Convention
1. all individuals possessing Romanian citizenship;
2. all legal persons, partnerships, associations and other entities set up according to the laws in force in Romania.

29-03-2018

Russian Federation

04-03-2015

1) Pursuant to Article 30, paragraph 1.a, of the Convention, the Russian Federation reserves the right not to provide any form of assistance in relation to the taxes of other Parties in any of the following categories listed in paragraph 1.b 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,
F. taxes on the use or ownership of movable property other than motor vehicles.
2) Pursuant to Article 30, paragraph 1.b, of the Convention, the Russian Federation 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.
3) Pursuant to Article 30, paragraph 1.f, of the Convention, the Russian Federation 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 Russian Federation, 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 Russian Federation.
Annex A – Taxes to which the Convention would apply
Article 2, paragraph 1.a
i. tax on income of individuals, tax on profits of organisations;
Article 2, paragraph 1.b
iii. B. tax on the property of organisations;
iii. C. value-added tax;
iii. D. excise tax;
iii. E. transport tax;
iii. G. any other taxes:
- water tax;
- mineral resource extraction tax;
- special tax regimes: taxation system for agricultural producers (uniform agricultural tax), simplified taxation system, taxation system in the form of uniform tax on the imputed income for individual kinds of activity, licence-based system of taxation;
- tax on gambling;
iv. land tax, tax on the property of individuals.
Annex B – Competent Authorities
The Russian Federation declares that the competent authorities of the Russian Federation listed in Annex B of the Convention are:
- the Federal Tax Service and its authorised representatives;
- the Federal Bailiff Service and its authorised representatives.

Rwanda

11-08-2021

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 sub-paragraph 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.
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.

Saint Kitts and Nevis

25-08-2016

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.

26-10-2016

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.

09-11-2017

Saint Lucia

21-11-2016

Pursuant to Article 30, paragraph 1.a, of the Convention, Saint Lucia reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in 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, and
iii A. estate, inheritance or gift taxes,
D. specific taxes on goods and services such as excise tax,
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 tax,
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, Saint Lucia 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.
Pursuant to Article 30, paragraph 1.c, of the Convention, Saint Lucia 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 Lucia 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 reservation by Saint Lucia.
Pursuant to Article 30, paragraph 1.d, of the Convention, Saint Lucia reserves the right not to provide assistance in the service of documents for the taxes described in Article 2, paragraph 1, of the Convention.
Pursuant to Article 9, paragraph 3, of the Convention, Saint Lucia 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 or
Withholding Tax
Article 2, paragraph 1.b.iii.B:
Land and House Tax
Stamp Duty
Article 2, paragraph 1.b.iii.C:
Value Added Tax
Annex B - Competent authorities
The Minister for Finance or his authorised representative.
Annex C - Definition of the word "national" for the purpose of the Convention
The term “national” means any individual possessing the citizenship of Saint Lucia, and any legal person, company, partnership or association deriving its status as such from the laws in force in Saint Lucia.

21-11-2016

Saint Vincent and the Grenadines

25-08-2016

31-08-2016

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.
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

31-08-2016

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.

San Marino

05-12-2014

Competent authority:
(Article 3, paragraph 1d)
The Ministry of Finance and Budget and Central Liaison Office - CLO

28-08-2015

In accordance with Article 30, paragraph 1.a, of the Convention, the Republic of San Marino does not provide any form of assistance in relation to the taxes of other Parties included in any of the categories listed in paragraph 1.b of Article 2 of the Convention.
In accordance with Article 30, paragraph 1.b, of the Convention, the Republic of San Marino does not provide assistance on recovering credits or fine for all taxes listed in paragraph 1 of Article 2 of the Convention.
In accordance with Article 30, paragraph 1.c, of the Convention, the Republic of San Marino does not provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention for the Republic of San Marino.
In accordance with Article 30, paragraph 1.d, of the Convention, the Republic of San Marino does not provide assistance for the service of documents for the taxes listed in paragraph 1 of Article 2 of the Convention.
In accordance with Article 30, paragraph 1.f, of the Convention, the Republic of San Marino 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 entry into force of the Convention, as amended by the 2010 Protocol, for the Republic of San Marino or, if there is no taxable period, for administrative assistance related to tax arising on or after 1 January of the third year preceding the entry into force of the Convention, as amended by the 2010 Protocol, for the Republic of San Marino.
Annex A – Taxes to which the Convention would apply
Article 2, paragraph 1.a.i: general income tax
(i) on individuals;
(ii) on bodies corporate and proprietorships;
[even if collected through a withholding tax]
Article 2, paragraph 1.a.ii: none
Article 2, paragraph 1.a.iii: none

25-09-2017

Considering that San Marino has committed to automatically exchange information 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, San Marino 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;
...
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

Saudi Arabia

17-12-2015

Article 30 (1) (a): The Kingdom of Saudi Arabia hereby declares that it reserves the right not to provide any form of assistance in relation to taxes of other parties in all of the categories listed in sub-paragraph (b) of paragraph (1) of Article 2 which are not included in Annex A of Saudi Arabia.
Article 30 (1) (b): The Kingdom of Saudi Arabia hereby declares that it reserves the right not to provide assistance in the recovery of tax claim, or in the recovery of an administrative fine, for all taxes, according to the provisions of Articles 11 and 12 of the convention.
Article 30 (1) (d): The Kingdom of Saudi Arabia hereby declares that it reserves the right not to provide assistance in the service of documents for all taxes.
Article 30 (1) (f): The Kingdom of Saudi Arabia hereby declares that it 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 Kingdom of Saudi Arabia, 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 Kingdom of Saudi Arabia.
Article 4 (3): the Kingdom of Saudi Arabia declares that its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7.
Article 9 (3): The Kingdom of Saudi Arabia hereby declares its intention not to accept, as a general rule, such requests from applicant States to allow representatives of the competent authority of the applicant State to be present at the appropriate part of a tax examination in the Kingdom of Saudi Arabia.
Article 29: The Kingdom of Saudi Arabia hereby declares that the territory to which this convention applies is the territory of the Kingdom of Saudi Arabia which also includes the area outside the territorial waters, where the Kingdom of Saudi Arabia exercises its sovereign and jurisdictional rights in their waters, sea bed, sub-soil and 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:
- The income tax including the natural gas investment tax
- The Zakat
Annex B - Competent authorities:
In relation to the Kingdom of Saudi Arabia, the term "competent authority" means the Ministry of Finance represented by the Minister of Finance or his authorised representative.

27-09-2018

06-01-2020

Amendment:
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

04-02-2016

Annex B - Competent authorities
The Minister of Economy, Finance and Planning or the Director General of Taxes and Domains

25-08-2016

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 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

30-08-2019

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.

Seychelles

25-06-2015

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.

09-01-2017

26-08-2019

Singapore

20-01-2016

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.
In accordance with Article 9, paragraph 3, of the Convention, the Republic of Singapore declares that it 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
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.
Annex B - Competent authorities
For the purposes of Article 3, paragraph 1.d, the term "competent authority" in relation to the Republic of Singapore means the Minister for Finance or his authorised representative.
Annex C – Definition of the term “national” for the purpose of the Convention
For the purposes of Article 3, paragraph 1.e, the term "national" in relation to the Republic of Singapore means
– any individual possessing the citizenship of Singapore; and
– any legal person, partnership or association deriving its status as such from the laws in force in Singapore.

19-12-2017

Interpretative Declaration
The Republic of Singapore understands that its commitments under this Convention do not derogate from the sovereign right of all States to choose their respective approaches to judicial penalties in accordance with their international law obligations. Further and in any event, the prescribed penalties under the Republic of Singapore’s tax laws are limited to fines and/or imprisonment. The Republic of Singapore is committed to respecting all constitutional rights and freedoms in her interpretation and implementation of the present Convention.
Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.
Considering that Singapore 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, Singapore has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 21 June 2017;
[...]
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

19-12-2017

Interpretative Declaration
The Republic of Singapore understands that its commitments under this Convention do not derogate from the sovereign right of all States to choose their respective approaches to judicial penalties in accordance with their international law obligations. Further and in any event, the prescribed penalties under the Republic of Singapore’s tax laws are limited to fines and/or imprisonment. The Republic of Singapore is committed to respecting all constitutional rights and freedoms in her interpretation and implementation of the present Convention.
Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.
Considering that Singapore intends to start automatically exchanging CbC Reports as of 2018 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”), Singapore has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 21 June 2017;
[...]
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

15-11-2019

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.

Slovakia

21-11-2013

Pursuant to Article 30, paragraph 1.a, of the Convention, the Slovak Republic reserves the right not to provide any form of assistance in relation to the taxes of other Parties in 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,
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 Slovak Republic reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for taxes in following categories listed in 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,
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 Slovak 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 in respect of the Slovak Republic.
Pursuant to Article 30, paragraph 1.d, of the Convention, the Slovak Republic reserves the right not to provide assistance in the service of documents for taxes in following categories listed in 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,
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.
Annex A - Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i:
Tax on income of individuals,
Tax on income of 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:
Motor vehicle tax.
Annex B - Competent Authorities
The Ministry of Finance or its authorised representative.
Annex C - Definition of a "national" for the purpose of the Convention
The term "national" means:
i. any individual possessing the nationality or citizenship of the Slovak Republic;
ii. any legal person, association and other entities deriving its status as such from the laws in force in the Slovak Republic.

28-08-2017

Slovenia

31-01-2011

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.
For the Republic of Slovenia, the Convention shall apply to those 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).
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.

05-07-2017

29-11-2017

South Africa

21-11-2013

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of South Africa 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; and
Article 2, paragraph 1.b.iv.
Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of South Africa 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.
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 B - Competent Authorities
The Commissioner for the South Africa revenue Service or an authorised representative of the Commissioner.
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.

22-11-2016

26-01-2017

Spain

10-08-2010

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.
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.
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.

19-10-2010

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.

10-12-2013

The Kingdom of Spain, following the notification, made by the OECD on 26 November 2013, of the decision by the United Kingdom of Great Britain and Northern Ireland to extend the application to Gibraltar of the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 Protocol, wishes to remind the declaration made at the time of the deposit of the instrument of ratification of the Convention:
"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."
Therefore, the following measures shall be followed:
a) All communications between the Organisation and its organs and Gibraltar shall be done through the British authorities, solely responsible for the international relations, of all kinds, for Gibraltar; also, all communications between States Parties to the Convention and Gibraltar shall be made through the British authorities, solely responsible for the international relations, of all kinds, for Gibraltar.
b) The presence of Gibraltar in any organ of the OECD within the framework of the Convention shall be done under the following heading: "Gibraltar Overseas Territory of the United Kingdom".
The application of the Convention to Gibraltar should not be interpreted as an acknowledgment of any right or any situation regarding areas not covered by Article X of the Treaty of Utrecht of 13 July 1713, concluded between the Crowns of Spain and of the United Kingdom.

22-08-2016

10-11-2017

Sweden

04-07-1990

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 (sjömansskatten)
the coupon tax (kupongskatten)
the tax on public entertainers (bevillningsavgiften för särskilda förmåner och rättigheter)
the tax on the undistributed profits of companies (ersättningsskatten)
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 förmögenhetsskatten)
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 allmän löneavgift]
- the Act (1984:668) on the Collection of Social Security Contributions from Employers [lagen (1984:668) om uppbörd av socialavgifter från arbetsgivare], and
- the Act (1989:484) on Work Environment Fee [lagen (1989:484) om arbetsmiljöavgift].
iii. A. The inheritance tax and the gift tax (arvsskatten och gåvoskatten).
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 mervärdeskatt].
D. Taxes according to the Act (1978:144) on Tax on certain travels [lagen (1978:144) om skatt på vissa resor], and the Act (1983:1053) on turnover tax on certain securities [lagen (1983:1053) om skatt på omsättning av vissa värdepapper].
E. Charges and taxes according to:
- the Road Traffic Tax Act (1973:601) [vägtrafikskattelagen (1973:601)]
- the Act (1976:338) on Road Traffic Tax on Vehicles which are not registered in Sweden [lagen (1976:388) om vägtrafikskatt på vissa fordon som inte är registrerade här i riket]
- the Act (1976:339) on Tax on Cars for Sale [lagen (1976:339) om saluvagnsskatt]
- the Road Traffic Tax Act (1988:327) [vägtrafiksskattelagen (1988:327)], and
- the Road Traffic Tax Act (1988:328) on foreign vehicles [lagen (1988:328) om vägtrafikskatt på utländska fordon].
G. Charges according to the Act (1972:435) on Fee on Excess Freight [lagen (1972:435) om överlastavgift].
Annex B - Competent authorities
(paragraph 1.d of Article 3 of the Convention)
The Minister of Finance or the National Tax Board.

03-09-2014

Pursuant to its decision of 15 May 2014, the Swedish Government informs of the changes in Swedish legislation on implementing the Council of Europe and OECD Convention on Mutual Administrative Assistance in Tax Matters (Annex A):
ANNEX A - Taxes to which the Convention would apply
Article 2, paragraph 1a:
i) Act (1970:624) on withholding tax on dividends, Act (1990:659) on special payroll tax, Act (1991:586) on special income tax and non-residents, Act (1991:591) on special income tax on non-resident artists and athletes, Act (1991:687) on special payroll tax on pension costs, Income tax act (1999:1229).
ii) Act (1990:661) on yield tax on pension funds.
iii) Wealth tax act (1997:323).
Article 2, paragraph 1b:
i) Funeral act (1990:1144), Act (1999:291) on fees to registered religious communities.
ii) Act (1994:1920) on general payroll fee, Act (1994:1744) on general pension contribution, Social security contribution act (2000:980).
iii) A. Act (1941:416) on inheritance tax and on gift tax.
B. Real estate tax act (1984:1052), Act (1984:404) on land register stamp duties.
C. Value added tax act (1994:200).
D. Act (1972:266) on tax on advertisements and advertising, Act (1972:820) on tax on gambling, Vehicle scrapping act (1975:343), Act (1984:409) on tax on fertilizer, Act (1984:410) on tax on pesticides, Act (1990:613) on an environmental charge on emissions of nitrogen oxides in energy production, Act (1990:1427) on premium tax on group life insurance, Lottery tax act (1991:1482), Act (1991:1483) on prize savings' tax, Tobacco excise duty act (1994:1563), Alcohol excise duty act (1994:1564), Act (1994:1776) on excise duty on energy, Act (1995:1667) on natural gravel tax, Act (1998:506) on monitoring of transportations etc. of alcohol merchandise, tobacco merchandise and mineral oil products subject to excise duties, Waste tax act (1999:673), Act (2000:466) on tax on thermal capacity in nuclear power reactors.
E. Act (1976:339) on tax on cars for sale, Vehicle tax act (1988:327), Act (1997:1137) on road user charges for certain heavy vehicles.
G. Act (1972:435) on overburden charge and Act (2014:52) on road infrastructures charges, as regards charges levied on public roads.

10-02-2016

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information:
Considering that Sweden 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, Sweden 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;
...
For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

05-07-2017

Switzerland

29-01-2016

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”.

26-09-2016

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”.

01-12-2017

Thailand

03-06-2020

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

22-12-2021

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.
Thailand 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.
ANNEX B – Competent Authorities The Minister of Finance or his authorised representative.
In accordance with Article 9, paragraph 3, of the Convention, Thailand 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 Thailand.

14-06-2023

14-09-2023

Tunisia

31-10-2013

The Republic of Tunisia declares that it will apply the provisions of the Convention only in respect of the Parties with which it has diplomatic relations.
Annex A - Taxes to which the Convention shall apply:
Article 2, paragraph 1.a.i:
- personal income tax,
- corporation tax.
Article 2, paragraph 1.a.ii:
- tax on capital gains of:
- transfer of buildings and building lands and social rights within real estate companies,
- transfer and retrocession of shares, partnership shares and fund shares and transfer and retrocession of rights on the related titles.
Article 2, paragraph 1.b.ii:
- social security contributions payable to general government or to social security institutions established under public law.
Article 2, paragraph 1.b.iii.A:
- taxes on registration of inheritance or gift.
Article 2, paragraph 1.b.iii.B:
- tax on immovable property.
Article 2, paragraph 1.b.iii.C:
- value added tax; consumption tax; registration and stamp duties returning to the State budget other than those referred to in paragraph 1.b.iii.A.
Article 2, paragraph 1.b.iii.D:
- single tax on insurance; taxes on turnover for the benefit of special treasury funds; road tax; stamp duties; compensation charges; visit tax; administrative formalities tax; telecommunications tax.
Article 2, paragraph 1.b.iv:
- taxes on buildings; taxes on building lands; taxes on industrial, commercial or professional buildings; hotel tax; entertainment tax; other taxes and duties for the benefit of local collectivities as provided by the Code of Local Taxation promulgated by Law No.97-11 of 3 February 1997.
Annex B - Competent Authorities
The Minister in charge of Finance or his authorised representatives.
Annex C - Definition of the word "national" for the purpose of the Convention
- any individuals possessing the Tunisian nationality, and
- any legal person, partnership, association and other organisation deriving their status as such from the legislation of Tunisia.

Türkiye

03-11-2011

Objection Cyprus, 19-12-2014

The Republic of Cyprus objects to the declaration deposited by the Republic of Turkey at the time of signature of the instrument on 3 November 2011, limiting the implementation of the provisions of the Convention and the Protocol only to the States with which the Republic of Turkey has diplomatic relations. The aforesaid declaration is contrary to the object and purpose of the Convention as it precludes the realization of the cooperation foreseen by the Convention between all member States of the Council of Europe, one of which is the Republic of Cyprus, and, as such, the said reservation is invalid.

Objection Armenia, 06-02-2020

26-03-2018

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.
Annex A – Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i:
- the income tax;
- the corporation 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:
--
Article 2, paragraph 1.b.iii:
A.: --
B.: --
C.: value added tax.
D.: --
E.: --
F.: --
G.: --
Article 2, paragraph 1.b.iv:
--
Annex B – Competent Authorities
The Minister of Finance or his authorised representative.
Annex C – Definition of the term "national" for the purpose of the Convention
All individuals possessing Turkish nationality in accordance with the Turkish Nationality Code, and all legal persons, partnership or association deriving their status as such from the laws in force in Turkey.
The Republic of Turkey declares, pursuant to Article 29, paragraph 1, of the Convention, that with respect to Turkey the Convention shall apply to the territory of the Republic of Turkey, including territorial sea and the airspace above it, as well as the maritime areas over which it has sovereign rights or jurisdiction for the purpose of exploration, exploitation and conservation of natural resources, pursuant to international law.
The Republic of Turkey declares that it will implement the provisions of this Convention and the Protocol only to the States Parties with which it has diplomatic relations.
Turkey declares that its ratification of the “Convention on Mutual Administrative Assistance in Tax Matters” neither amounts to any form of recognition of the Greek Cypriot Administration’s pretention to represent the defunct “Republic of Cyprus” as party to the Convention, nor should it imply any obligations on the part of Turkey to enter into any dealing with the so-called Republic of Cyprus within the framework of the said Convention.
The Republic of Cyprus was founded as a Partnership State in 1960 by Greek and Turkish Cypriots in accordance with international treaties. This partnership was destroyed by the Greek Cypriot side when it unlawfully seized the state by forcibly ejecting all Turkish Cypriot members in all the state organs in 1963. Eventually, Turkish Cypriots who were excluded from the Partnership State in 1963 have organized themselves under their territorial boundaries and exercise governmental authority, jurisdiction and sovereignty. There is no single authority which in law or in fact is competent to represent jointly the Turkish Cypriots and the Greek Cypriots and consequently Cyprus as a whole. Thus, the Greek Cypriots cannot claim authority, jurisdiction or sovereignty over the Turkish Cypriots who have equal status, or over the entire Island of Cyprus.

Objection Armenia, 06-02-2020

Uganda

26-05-2016

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Uganda 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: 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 gains.
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.
Article 2, paragraph 1.b.iii.D:
• Excise Tax.
Annex B - Competent authorities
The Commissioner General of the Uganda Revenue Authority or an authorised 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, partnership or other entity deriving its status as such from the laws in force in Uganda.

Ukraine

26-03-2009

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 motor 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.
Annex B - Competent authorities
The State Tax Administration of Ukraine;
The State Customs Service of Ukraine;
The Pension Fund of Ukraine.
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.
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.

United Arab Emirates

22-09-2017

21-05-2018

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.e, 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.

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 authorised 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.

United Kingdom

11-02-2008

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).
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.
Annex A - Taxes to which the Convention applies
For the United Kingdom of Great Britain and Northern Ireland, the Convention shall apply to those 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)
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.
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.

25-06-2013

20-08-2013

25-09-2013

13-11-2013

19-11-2013

The Government of the United Kingdom of Great Britain and Northern Ireland declares that the United Kingdom's ratification of the Convention as amended by its Protocol shall be extended to the territory of the British Virgin Islands, for whose international relations the United Kingdom is responsible.
Pursuant to Article 30, paragraph 1(a), of the Convention, the Government of the British Virgin Islands will not provide any form of assistance in relation to the taxes of other Parties described in Article 2, paragraph 1(b)(i), (iii)(A), (iii)(C), (iii)(D), (iii)(E), (iii)(F), (iii)(G) or (iv), of the Convention.
Pursuant to Article 30, paragraph 1(b), of the Convention, the Government of the British Virgin Islands 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 the British Virgin Islands will not provide assistance in respect of any tax claims, which is in existence at the date of entry into force of the Convention in the British Virgin Islands or, where a reservation has previously been made under Article 30, paragraphs 1(a) or 1(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(f), of the Convention, the Government of the British Virgin Islands will 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 the British Virgin Islands, 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 the British Virgin Islands.
Annex A - Taxes to which the Convention applies
For the British Virgin Islands, the Convention shall apply to those taxes in Article 2, paragraph 1, which fall within paragraphs (ii) or (iii)(B) of sub-paragraph (b).
Annex B - Competent authorities
The competent authority for the British Virgin Islands shall be the International Tax Authority - Ministry of Finance.
Annex C - Definition of the word "national" for the purpose of the Convention
In relation to the British Virgin Islands, the term "national" means any person who belongs to the British Virgin Islands within the meaning of section 2(2) of the Virgin Islands Constitution Order 2007 S.I.2007/1678 and any legal person, partnership, association or other entity deriving its status as such from the laws in force in the British Virgin Islands.

19-11-2013

21-11-2013

The Government of the United Kingdom of Great Britain and Northern Ireland declares that the United Kingdom's ratification of the Convention as amended by its Protocol shall be extended to the territory of the Isle of Man, for whose international relations the United Kingdom is responsible.
Pursuant to Article 30, paragraph 1(a), of the Convention, the Government of the Isle of Man will not provide any form of assistance in relation to the taxes of other Parties 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 Government of the Isle of Man will not 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.
Pursuant to Article 30, paragraph 1(c), of the Convention, the Government of the Isle of Man 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), in relation to taxes of the category in question.
Pursuant to Article 30, paragraph 1(d), of the Convention, the Government of the Isle of Man 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 the Isle of Man 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 Isle of Man, the Convention shall apply the following taxes:
Article 2, paragraph (1)(a)(i):
Income Tax.
Annex B - Competent authorities
The competent authority for the Isle of Man shall be the Assessor of Income Tax or his or her delegate.
Annex C - Definition of the word "national" for the purpose of the Convention
In relation to the Isle of Man, the term "national" means any individual who has a right of abode in the Isle of Man and possesses British citizenship and any legal person, partnership or association deriving its status as such under the laws of the Isle of Man.

17-02-2014

The Government of the United Kingdom of Great Britain and Northern Ireland declares that the United Kingdom's ratification of the Convention as amended by its Protocol shall be extended to the territory of the Bailiwick of Jersey, for whose international relations the United Kingdom is responsible for.
Pursuant to Article 30, paragraph 1(a), of the Convention, the Government of Jersey reserves the right not to 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 Jersey will not 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.
Pursuant to Article 30, paragraph 1(c), of the Convention, the Government of Jersey will not provide any form of 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 Jersey 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 Jersey will not permit the service of documents through the post.
Annex A - Taxes to which the Convention applies
For the Bailiwick of Jersey, the Convention shall apply to those taxes in Article 2, paragraph 1, which fall within:
- paragraph (a)(i): taxes on income or profits,
- paragraph (a)(ii): taxes on capital gains which are imposed separately from the tax on income or profits,
- paragraph (a)(iii): taxes on net wealth.
Annex B - Competent authorities
The competent authority for the Bailiwick of Jersey shall be the Treasury and Resources Minister or his authorised representative.
Annex C - Definition of the word "national" for the purpose of the Convention
In relation to the Bailiwick of Jersey, the term "national" means any citizen of the Bailiwick of Jersey and any legal person, partnership or association deriving its status as such from the laws in force in the Bailiwick of Jersey.

19-02-2014

The Government of the United Kingdom of Great Britain and Northern Ireland declares that the United Kingdom's ratification of the Convention as amended by its Protocol shall be extended to the territory of Bermuda, for whose international relations the United Kingdom is responsible, including any area outside the territorial sea of Bermuda designated under its laws concerning the Continental Shelf and in accordance with international law, and any further area in accordance with international law as an area within which the rights of Bermuda with respect to the sea, the sea bed and subsoil and their natural resources may be exercised.
Pursuant to Article 30, paragraph 1(a), of the Convention, the Government of Bermuda 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 Bermuda 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 Bermuda will not provide any form of assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention for Bermuda or, where a reservation has been made, 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 Government of Bermuda will not provide assistance in the service of documents for all taxes.
Pursuant to Article 30, paragraph 1(f), of the Convention, the Government of Bermuda will not provide assistance for tax matters involving intentional conduct that may be prosecuted under the criminal law of a Party, unless such matters are for periods beginning on or after 1 January of the third year preceding the year of entry into force of the Convention for Bermuda, 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 year of entry into force of the Convention for Bermuda.
Annex A - Taxes to which the Convention applies
In respect of Bermuda, there are no applicable taxes falling within Article 2, paragraph 1(a).
Annex B - Competent authorities
The competent authority for Bermuda shall be the Minister of Finance or its authorised representative.
Annex C - Definition of the word "national" for the purpose of the Convention
In relation to Bermuda, the term "national" means any individual possessing Bermudian Status as defined in accordance with paragraph 102(3) of Schedule 1 to the Bermuda Constitution Order S.I. 1968/182, and any legal person, partnership, company, trust, estate, association or other entity created under the laws in force in Bermuda.

19-02-2014

Revised communication of 19-11-2013:
[...]
Pursuant to Article 30, paragraph 1(a), of the Convention, the Government of Gibraltar 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 Gibraltar 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 Gibraltar 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 Gibraltar 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 Gibraltar will not permit the service of documents through the post.
Annex A - Taxes to which the Convention applies
For Gibraltar, the Convention shall apply to those taxes in Article 2, paragraph 1, which fall within paragraph (a)(i).
Annex B - Competent authorities
The competent authority for Gibraltar shall be the Commissioner of Income Tax of the Government of Gibraltar.
Annex C - Definition of the word "national" for the purpose of the Convention
In relation to Gibraltar, the term "national" means a Gibraltarian within the meaning of the Gibraltarian Status Act 1962 and any legal person, partnership or association deriving its status as such from the laws in force in Gibraltar.

17-04-2014

The Government of the United Kingdom of Great Britain and Northern Ireland declares that the United Kingdom's ratification of the Convention as amended by its Protocol shall be extended to the territory of the Bailiwick of Guernsey, for whose international relations the United Kingdom is responsible.
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.

19-12-2016

16-05-2017

The Government of Bermuda expresses its wish to amend its reservations made at the time of the extension of the United Kingdom’s ratification of the Convention to the territory of Bermuda.
Pursuant of Article 30, paragraph 4, the following reservations in respect of Bermuda are withdrawn:
Article 30, paragraph 1.a,
Article 30, paragraph 1.c,
Article 30, paragraph 1.f.

16-05-2017

The Permanent Delegation of the United Kingdom to the Organisation for Economic Co-operation and Development presents its compliments to the Secretary-General of the OECD and wishes to inform him that the Letters of Entrustment prepared by the United Kingdom (UK) in relation to the Organisation for Economic Cooperation and Development (OECD)/Council of Europe (CoE) Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAAC) entrust the UK Overseas Territories (OTs) and Crown Dependencies (CDs) to take action under the MAAC, including to enter into agreements with other State parties in that respect.
The Letters of Entrustment permit the OTs and CDs to “take action”, which includes, but is not limited to, undertaking the following activities:
- Modifying Annex A (Article 2.3 of the MAAC);
- Modifying Annex B (Article 3.3 of the MAAC);
- Concluding agreements on the automatic exchange of information in compliance with the procedure in Article 6 of the MAAC;
- Issuing a declaration in compliance with the procedure in Article 4.3 of the MAAC;
- Issuing a declaration under Article 9.3 of the MAAC; and
- Agreeing on an earlier date of effect for administrative assistance related to earlier taxable periods or charges to tax as provided for in Article 28.6 of the MAAC, and issuing associated declarations.
The Letters of Entrustment also permit the OTs and CDs to modify their reservations in compliance with Article 30.3 of the MAAC.
The OTs and CDs must notify the United Kingdom in advance of taking such action under the MAAC.
The United Kingdom can confirm that the Letters of Entrustment:
- do not include the possibility for the OTs to withdraw the territorial extension of the MAAC (under Article 29.3) without the United Kingdom’s authorisation;
- do not include the possibility for the CDs to withdraw the territorial extension of the MAAC (under Article 29.3) without first consulting the United Kingdom;
- do not change the United Kingdom’s role as the sole representative in the Co-ordinating Body of the MAAC; and
- provide that the OTs and CDs will be able to “take action in respect of their own jurisdictions under the Convention” which means that each jurisdiction can only take action in respect of itself (including taking some actions usually reserved to parties in respect of itself) and not the United Kingdom or another jurisdiction.

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Note by the Secretariat: The United Kingdom Overseas Territories and Crown Dependencies concerned by this Communication are Anguilla, Bermuda, the British Virgin Islands, the Cayman Islands, Gibraltar, Guernsey, the Isle of Man, Jersey, Montserrat and the Turk and Caicos Islands.

24-05-2017

17-07-2017

25-07-2017

14-12-2017

25-07-2023

United States of America

13-02-1991

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).
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).
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.

05-12-1991

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.

Uruguay

31-08-2016

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.

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 Económicas - IRAE);
- Personal income tax (Impuesto a las Rentas de las Personas Físicas - 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 Específico Interno - IMESI)
Annex B – Competent Authorities
The Minister of Economy and Finance or his authorised représentative.
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.

27-04-2018

30-01-2019

Vanuatu

23-08-2017

Annex A – Taxes to which the Convention would apply:
Article 2, paragraph 1.a.i:
- Business Licence fees (including turnover tax)
- Casino fees and taxes
- Gaming fees and taxes
- Internet gaming fees and taxes
- Lottery taxes
Article 2, paragraph 1.b.iii.B:
- Stamp duties
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:
- Vehicle registration and transfer fees and taxes
- Road taxes
Article 2, paragraph 1.b.iii.F:
- Stamp duties
Article 2, paragraph 1.b.iii.G:
- Rent tax
Annex B – Competent Authorities
The Minister of Finance or his or her authorised representative.
Annex C - Definition of the word "national" for the purpose of the Convention
In relation to Vanuatu, the term “national” means any individual possessing the citizenship of Vanuatu, and any legal person, company, partnership or association deriving its status as such from the laws in force in Vanuatu.

22-06-2018

Annex B - Competent authorities:
The Minister of Finance or its authorised representative.

Vietnam

22-03-2023

In accordance with Article 30, paragraph 1.a, of the Convention, Viet Nam reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in the categories listed in Article 2, paragraph 1, sub-paragraphs b.i, b.ii, b.iii.A, B, D, E, F and G and b.iv of the Convention.
In accordance with Article 30, paragraph 1.b, of the Convention, Viet Nam 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, Viet Nam 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 Viet Nam, or reserved according to Article 30, paragraphs 1.a and 1.b, of the Convention at the date of withdrawal of such a reservation by Viet Nam.
In accordance with Article 30, paragraph 1.d, of the Convention, Viet Nam reserves the right not to provide assistance in the service of documents for all taxes included in the categories listed in Article 2, paragraph 1, sub-paragraphs b.i, b.ii, b.iii.A, B, D, E, F and G and b.iv of the Convention.
In accordance with Article 30, paragraph 1.f, of the Convention, Viet Nam 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 Viet Nam, 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 Viet Nam.
In accordance with Article 9, paragraph 3, of the Convention, Viet Nam does not accept requests aiming to allow representatives of the competent authority of the applicant State to be present at tax examinations in Viet Nam.
Viet Nam signs 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:
. the personal income tax;
. the business income tax.
Article 2, paragraph 1.b.iii.C: the value-added tax.
ANNEX B – Competent Authorities
In relation to Viet Nam, the term “competent authority” means the Minister of Finance or his authorized representative.

31-08-2023

In accordance with Article 30, paragraph 1.a, of the Convention, Viet Nam reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in the categories listed in Article 2, paragraph 1, sub-paragraphs b.i, b.ii, b.iii.A, B, D, E, F and G and b.iv of the Convention.
In accordance with Article 30, paragraph 1.b, of the Convention, Viet Nam 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, Viet Nam 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 Viet Nam, or reserved according to Article 30, paragraphs 1.a and 1.b, of the Convention at the date of withdrawal of such a reservation by Viet Nam.
In accordance with Article 30, paragraph 1.d, of the Convention, Viet Nam reserves the right not to provide assistance in the service of documents for all taxes included in the categories listed in Article 2, paragraph 1, sub-paragraphs b.i, b.ii, b.iii.A, B, D, E, F and G and b.iv of the Convention.
In accordance with Article 30, paragraph 1.f, of the Convention, Viet Nam 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 Viet Nam, 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 Viet Nam.
In accordance with Article 9, paragraph 3, of the Convention, Viet Nam does not accept requests aiming to allow representatives of the competent authority of the applicant State to be present at tax examinations in Viet Nam.
Viet Nam approves 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:
. the personal income tax;
. the business income tax.
Article 2, paragraph 1.b.iii.C: the value-added tax.
ANNEX B – Competent Authorities
In relation to Viet Nam, the term “competent authority” means the Minister of Finance or his authorized representative.

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