Convention on Mutual Administrative Assistance in Tax Matters

Party

Japan modified

• added reservation
  05-01-2026
  Pursuant to paragraph 4 of Article 2 of the Convention on Mutual Administrative Assistance in Tax Matters, the Government of Japan wishes to add “the special corporation tax for defence” to Annex A (sub-paragraph (a)(i)). “The special corporation tax for defence” 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 corporation tax for defence” is intended to apply to taxable years on and after 1 April 2026, the Convention shall apply to “the special corporation tax for defence” from the same date.

Party

Fiji added

• Signature: 15-01-2026
• Reservations / Declarations: No
• Objections: No

Party

Madagascar modified

• Ratification: 28-07-2025 (R)
• Entry into force: 01-11-2025
• Reservations / Declarations: Yes

• added reservation
  28-07-2025
  Madagascar ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol with the following reservations and declarations: In accordance with Article 30, paragraph 1.a, of the Convention, Madagascar reserves the right not to 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; and iii. Taxes in other categories imposed on behalf of a Party, namely: 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. In accordance with Article 30, paragraph 1.c, of the Convention, Madagascar will not provide assistance in respect of any tax claim which is already in existence at the date of entry into force of the Convention in its respect. In accordance with Article 30, paragraph 1.f of the Convention, Madagascar reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on 1 January, 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 Madagascar, or where there is no taxable period, for administrative assistance related to charges to tax arising on 1 January 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 Madagascar. Annex A – Taxes to which the Convention would apply Article 2, paragraph 1.a.i: - Income Tax - Direct tax on hydrocarbons - Tax on public procurement - Combined tax - Taxes on wage and salary income and similar taxes - Taxes on income from movable capital - Tax on capital gains on real estate Article 2, paragraph 1.b.iii.A: Estate and Donor’s Taxes. Article 2, paragraph 1.b.iii.B: Land tax on land (IFT) and Land tax on built property (IFPB). Article 2, paragraph 1.b.iii.C: Value Added Tax. Article 2, paragraph 1.b.iii.D: Excise Taxes. Annex B – Competent authority The Director General of Taxes.

Zimbabwe added

• Signature: 31-07-2025
• Reservations / Declarations: No
• Objections: No

Party

Sweden modified

• added reservation
  07-05-2025
  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 Swedish Government notifies the following amendments to its declaration to Annex A. List of Swedish taxes and charges to which the Convention applies The Convention applies to taxes and charges levied under the following acts: Article 2 paragraph 1 a: i) Act (1970:624) on withholding tax on dividends, Act (1990:659) on special payroll tax, Act (1991 :5 86) on special income tax on non-residents, Act (1 991 :59 1) on special income tax on non-resident artistes 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 1 b: 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 actQ000:98O). 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 (2023:200). 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 (1984:4 10) on tax on pesticides, Act (1990:6 13) 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: 14.82), Act (1991:1483) on prize savings’ tax, Act (1994:1776) on excise duty on energy, Act (1995:1667) on natural gravel tax, Act (1998:506) on the movement and control of certain goods subject to excise duty, Waste tax act (1999:673), Act (2000:466) on tax on thermal capacity in nuclear power reactors, Tobacco excise duty act (2022:155), Alcohol excise duty act (2022:156). E. Act (1997 1137) on road user charges for certain heavy vehicles, Act (2006:227) on road traffic tax, and Act (2006:228) with special provisions on vehicle tax. F. Act (1972:43 5) on overburden charge, Act (2004:629) on congestion charge, and Act (2024:172) on road infrastructure charges, as regards charges levied on public roads.

Party

Honduras modified

• Reservations / Declarations: Yes

• added reservation
  27-02-2025
  In accordance with Article 3, paragraph 3, of the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 Protocol (hereinafter “the Convention”), Honduras notifies that the competent authority designated for the purposes of Article 3, paragraph 1.d, of the Convention is the Minister of Finance or its authorized representative.

Vietnam modified

• added reservation
  31-01-2025
  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 Competent Authority, as designated by Viet Nam in its notification under Annex B of the MAAC, intends to start automatically exchanging CbC Reports as of 2025 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 Competent Authority, as designated by Viet Nam in its notification under Annex B of the MAAC, has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 3rd January 2025; […] [For the further content of the declaration, please refer to the declarations transmitted by Germany on 24 February 2017 regarding financial account information and country-by-country reports, mutatis mutandis.]

Party

Côte d'Ivoire added

• Signature: 23-04-2025
• Reservations / Declarations: No
• Objections: No

Party

Argentina modified

• added reservation
  31-01-2025
  In accordance with Article 3, paragraph 3 […], the Republic of Argentina notifies that the competent authority designated for the purposes of Article 3, paragraph 1.d, of the Convention is modified as follows: The Agency for Tax Collection and Customs Supervision (Agencia de Recaudación y Control Aduanero (ARCA)).

Party

Philippines modified

• Ratification: 07-01-2025 (R)
• Entry into force: 01-05-2025
• Reservations / Declarations: Yes

• added reservation
  07-01-2025
  The Republic of the Philippines ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol with the following reservations and declarations: In accordance with Article 30, paragraph 1.a of the Convention, the Republic of the Philippines reserves the right not to 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: 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; and 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. In accordance with Article 30, paragraph 1.b of the Convention, the Republic of the Philippines 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. In accordance with Article 30, paragraph 1.c of the Convention, the Republic of the Philippines 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 Philippines or, where a reservation has previously been made under subparagraph a or b 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 the Philippines reserves the right not to provide assistance in the service of documents for all taxes described in Article 2, paragraph 1. In accordance with Article 30, paragraph 1.e of the Convention, the Republic of the Philippines reserves the right not to permit the service of documents through the post as provided in Article 17, paragraph 3 for all taxes. In accordance with Article 30, paragraph 1.f of the Convention, the Republic of the Philippines reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 01 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 the Philippines, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 01 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 the Philippines. Annex A – Taxes to which the Convention would apply Article 2, paragraph 1.a.i: Income Tax (Title II of the National Internal Revenue Code [NIRC] of 1997, as amended) Article 2, paragraph 1.b.iii.A: Estate and Donor’s Taxes (Title III of the NIRC) Article 2, paragraph 1.b.iii.C: Value Added Tax (Title IV of the NIRC). Article 2, paragraph 1.b.iii.D: Excise Taxes (Title VI of the NIRC). Annex B – Competent authority Pursuant to Article 3, paragraph the Convention, the Government of the Republic of the Philippines declares that “competent authority” means the Secretary of Finance or his authorized representative. Annex C – Definition of a "national" for the purpose of the Convention In relation to the Republic of the Philippines, the term “national” means any individual possessing the nationality or citizenship of the Republic of the Philippines; and any legal person, company, partnership or association deriving its status as such from the laws in force in the Republic of the Philippines.

Party

Trinidad and Tobago modified

• added reservation
  03-12-2024
  The Republic of Trinidad and Tobago ratified the Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol with the following declarations: Annex A – Taxes to which the Convention would apply Article 2, paragraph 1.a.i: - Income Tax; - Corporation Tax; - Business Levy; - Petroleum Profits Tax; - Supplemental Petroleum Tax; - Unemployment Levy. Article 2, paragraph 1.b.iii.C: Value Added Tax. Annex B – Competent authority The Minister of Finance or his authorised representative.

Party

Trinidad and Tobago modified

• Ratification: 03-12-2024 (R)
• Entry into force: 01-04-2025