ContractCompetent Authority Agreement • April 10th, 2018
Competent Authority Agreement between the Isle of Man and Guernsey on the Exchange of Country-by-Country ReportsCompetent Authority Agreement • August 3rd, 2017
Whereas, the Government of the Isle of Man and the States of Guernsey desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which Multinational Enterprise (MNE) Groups operate through the automatic exchange of annual CbC Reports, with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • December 9th, 2004
The competent authorities of the United States and Switzerland hereby enter into the following agreement (“the Agreement”) regarding the qualification of certain U.S. and Swiss pension or other retirement arrangements for benefits under paragraph 3 of Article 10 (Dividends) of the Convention Between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income signed at Washington on October 2, 1996 (“the Treaty”). The Agreement specifies the procedures for claiming Treaty benefits in each country and the methods each country will use to grant Treaty benefits. The Agreement is entered into under paragraph 3 of Article 25 (Mutual Agreement Procedure).
Competent Authority Agreement under the Ireland-Malta Double Taxation Convention 2008Competent Authority Agreement • October 22nd, 2018
The information in this document is provided as a guide only and is not professional advice, including legal advice. It should not be assumed that the guidance is comprehensive or that it provides a definitive answer in every case.
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • April 12th, 2005
The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the qualification of certain U.K. pension or other retirement arrangements for benefits under paragraph 3(b) of Article 10 (Dividends) of the Convention Between the United States of America and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation with Respect to Taxes on Income signed at London on July 24, 2001 (“the Treaty”). The Agreement is entered into under paragraph 3 of Article 26 (Mutual Agreement Procedure).
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • February 5th, 2013
The Competent Authorities of the United States and Norway hereby enter into the following mutual agreement regarding the eligibility of entities that are treated as fiscally transparent under the laws of either Contracting State to benefit under the Convention Between the United States of America and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property, signed on December 3, 1971, and as amended by the Protocol signed on September 19, 1980 (the “Treaty”). This agreement clarifies the cases in which fiscally transparent entities are entitled to treaty benefits and clarifies the procedure for claiming treaty benefits from Norway. The agreement is entered into under paragraph 2 of Article 27 (Mutual Agreement Procedure) of the Treaty.
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • March 21st, 2018
The competent authorities of Switzerland and the Netherlands (hereinafter: “the competent authorities”) have reached the following mutual agreement regarding the application of the Convention between the Kingdom of the Netherlands and the Swiss Confederation for the avoidance of double taxation with respect to taxes on income signed at The Hague on February 26th, 2010 and the related Protocol ("the Convention") with respect to a Netherlands fiscal investment institution (fiscale beleggingsinstelling, "FBI"), by a Swiss contractual fund (fonds commun de placement, "FCP") and a Swiss open ended investment fund (société d’investissement à capital variable, "SICAV"). This Competent Authority Agreement (“Agreement”) is entered into under Article 25, paragraph 3 (Mutual Agreement Procedure) of the Convention.
Competent Authority AgreementCompetent Authority Agreement • May 28th, 2020
Whereas, the Isle of Man and the British Virgin Islands intend to increase international tax transparency and improve the access of tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which Multinational Enterprise (MNE) Groups operate through the automatic exchange of annual CbC Reports, with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • March 26th, 2010
The competent authorities of the United States and Belgium hereby enter into the following agreement (the “Agreement”) regarding the types of pension plans established in either Contracting State that will be deemed to generally correspond to a pension plan recognized for tax purposes in the other Contracting State as required by paragraphs 7 and 9 of Article 17 (Pensions, Social Security, Annuities, Alimony, and Child Support) of the Convention Between the Government of the United States of America and the Government of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income signed at Brussels on November 27, 2006 (the “Treaty”). The Agreement is entered into under paragraph 3 of Article 24 (Mutual Agreement Procedure).
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • September 17th, 2010
This Agreement applies to closed FGRs formed in conformity with the Decree of 11 January 2007, CPP2006/1870M, Dutch. Gov. Gaz. No 15, 2007. A closed FGR can act as a pooled investment vehicle for the assets of pension funds and other investors. The closed FGR invests these assets on behalf of those investors.
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • October 8th, 2014
The competent authorities of the United Kingdom and the Netherlands have reached the following mutual agreement regarding the application of the Convention between the Government of the Kingdom of the Netherlands and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains and the related Protocol signed on 26 September 2008 to UK pension scheme and Charity investors in UK Common Investment Funds (hereinafter also referred as: ‘CIFs’).
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • January 21st, 2010
This Agreement is entered into pursuant to paragraph 3(a)(aa) of Article 1 and paragraph 3 of Article 25 (Mutual Agreement Procedure) of the Tax Treaty.
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • August 20th, 2020
Pursuant to Article 23(3) of the Convention between the Republic of Austria and the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains, signed on 23 October 2018, (hereinafter “the Convention”),
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • February 7th, 2017
Pursuant to Article 25(3) of the Convention between the Government of the Kingdom of the Netherlands and the Government of the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • March 26th, 2010
The Competent Authorities of the Netherlands and the United States hereby amend Chapter III of the agreement that they entered into on August 6, 20071 (the “2007 MAP”), with respect to the “qualification” certification procedure used by certain U.S. tax-exempt trusts, companies, or other organizations for claiming treaty benefits from the Netherlands under Article 35 of the Convention between the Kingdom of the Netherlands and the United States of America for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed on December 18, 1992, and amended by Protocols signed on October 13, 1993 and March 8, 2004 (the “Treaty”). This agreement constitutes a Mutual Agreement in accordance with Article 29 of the Treaty.
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • March 2nd, 2006
The Competent Authorities of the United States and Ireland enter into the following agreement (“Agreement”) concerning the treatment of Common Contractual Funds under the Convention Between the Government of the United States of America and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed at Dublin on July 28, 1997 (the “Treaty”) and the Protocol, also signed at Dublin on July 28, 1997 (the “Protocol”). The Agreement is entered into under paragraph 3 of Article 26 (Mutual Agreement Procedure).
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • February 25th, 2009
The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first notification” under paragraph 1 of Article 26 (Mutual Agreement Procedure) of the Convention between the United States of America and the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation with respect to taxes on income signed at London on July 24, 2001 (“the Treaty”). The Agreement is entered into under paragraph 3 of Article 26 (Mutual Agreement Procedure).
ContractCompetent Authority Agreement • November 3rd, 2014
COMPETENT AUTHORITY AGREEMENT REGARDING THE INTERPRETATION OF ARTICLE 19 OF THE AGREEMENT BETWEEN THE GOVERNMENT OF THE PEOPLE'S REPUBLIC OF CHINA AND THE GOVERNMENT OF THE UNITED STATES OF AMERICA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • February 25th, 2009
The Competent Authorities of the Netherlands and the United States hereby amend and restate the agreement that they entered into on March 23, 20001, with respect to the qualification of certain tax-exempt trusts, companies, or other organizations for benefits under Article 35 of the Convention between the Kingdom of the Netherlands and the United States of America for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed on December 18, 1992, and amended by Protocols signed on October 13, 1993 and March 8, 2004 (the “Treaty”). The agreement specifies the procedures for claiming treaty benefits in each country and the methods each country will use to grant treaty benefits.
Agreement of August 20, 2003, regarding the Limitation on Benefits Article 22 of the Income Tax Treaty between the United States and the Swiss ConfederationCompetent Authority Agreement • September 20th, 2010
The Competent Authorities of the United States and the Swiss Confederation enter into the following Agreement ("Agreement") concerning the ownership requirements under paragraph 3 of Article 22 (Limitation on Benefits) and paragraph 7 (In reference to paragraph 6 of Article 22 (Limitation on Benefits)) of the Revised Memorandum of Understanding ("MOU") of the Convention Between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income, signed on October 2, 1996 ("Treaty"). The Agreement is entered into under paragraph 3 of Article 25 (Mutual Agreement Procedure).
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • March 3rd, 2013
The Competent Authorities of the United States and Norway hereby enter into the following mutual agreement (“Agreement”). The Agreement specifies the meaning of profits derived from the transportation by ship or aircraft of supplies or personnel to a location where activities in connection with the exploration or exploitation of the seabed and sub-soil and their natural resources are being carried on in the other Contracting State, or from the operation of tugboats and similar vessels in connection with such activities. The Agreement is entered into under paragraph 2 of Article 27 (Mutual Agreement Procedure) of the Convention Between the United States of America and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property, signed December 3, 1971, and as amended by the Protocol signed September 19, 1980 (the “Treaty”).
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • April 3rd, 2012
The Competent Authorities of the Federal Republic of Germany and the United States of America hereby enter into the following agreement (the “Agreement”) regarding the eligibility of certain pension arrangements for benefits under paragraph 3(b) of Article 10 (Dividends) of the Convention Between the United States of America and Germany for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital and to Certain Other Taxes, together with a related Protocol signed on August 29, 1989, and amended by the Protocol signed on June 1, 2006 (the “Treaty”). The Agreement is entered into under paragraph 3 of Article 25 (Mutual Agreement Procedure) of the Treaty.
Competent Authority AgreementCompetent Authority Agreement • October 20th, 2009
The competent authorities of the United States of America and the Kingdom of Belgium, pursuant to Article 24 (Mutual Agreement Procedure) of the US- Belgium income tax treaty (“Treaty”) hereby agree that under Treaty Article 21 (Limitation on Benefits), the determination of whether a person is an “equivalent beneficiary” under subparagraphs 3 a) and 8 g) is to be made taking into account the following language:
Competent Authority AgreementCompetent Authority Agreement • September 28th, 2016
The Competent Authorities of Ireland and Switzerland enter into the following agreement concerning the correct application of paragraph 3 of Article 3 of the Convention between Ireland and Switzerland for the avoidance of double taxation with respect to taxes on income and capital (the "Convention"). The Competent Authority Agreement is entered into under paragraph 3 of Article 25 (Mutual Agreement Procedure) of the Convention.
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • April 12th, 2016
The competent authorities of Switzerland and the Netherlands (hereinafter: “the competent authorities”) have reached the following mutual agreement regarding the application of the Convention between the Kingdom of the Netherlands and the Swiss Confederation for the avoidance of double taxation with respect to taxes on income signed at The Hague on February 26th, 2010 and the related Protocol ("the Convention") with respect to a Netherlands a fiscal investment institution (fiscale beleggingsinstelling, "FBI"), by a Swiss contractual fund (fonds commun de placement, "FCP") and a Swiss open ended investment fund (société d’investissement à capital variable, "SICAV"). This Competent Authority Agreement (“Agreement”) is entered into under Article 25, paragraph 3 (Mutual Agreement Procedure) of the Convention.
Swiss Agreement on Treaty Benefits Announcement 2003–59Competent Authority Agreement • April 19th, 2022
The following is a copy of the agree- ment concluded between the U.S. and Swiss competent authorities on August 20, 2003 and released on August 22, 2003 (IR–2003–103) regarding the Limitation of Benefits Article of the income tax treaty and accompanying Revised Memorandum of Understanding between the United States and the Swiss Confederation.
ContractCompetent Authority Agreement • March 21st, 2016
ContractCompetent Authority Agreement • February 15th, 2011
COMPETENT AUTHORITY AGREEMENT REGARDING THE INTERPRETATION OF ARTICLE 19 OF THE AGREEMENT BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE PEOPLE'S REPUBLIC OF CHINA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
Austria Agreement on Deferred PaymentsCompetent Authority Agreement • November 24th, 2022
Austrian Competent Authorities have entered into a competent authority agreement. This agreement provides that the U.S.-Austria Income Tax Treaty signed on October 25, 1956, does not prohibit Austria from taxing deferred payments for services earned by U.S. citizens while working and re- siding in the United States, when such compensation was paid after these em- ployees became residents of Austria. The agreement also confirms, however, that Austria shall deduct from its tax the amount of U.S. taxes imposed on the deferred payments for services, as re- quired by the treaty. The 1956 income tax treaty is applicable for assessment periods up to and including 1998.
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • September 2nd, 2020
Pursuant to Article 23(3) of the Convention between the Republic of Austria and the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains, signed on 23 October 2018, (hereinafter “the Convention”),
Competent Authority AgreementCompetent Authority Agreement • October 3rd, 2018
Whereas, the Isle of Man and the Turks and Caicos Islands intend to increase international tax transparency and improve access tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which Multinational Enterprise (MNE) Groups operate through the automatic exchange of annual CbC Reports, with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • October 10th, 2016
On November 28, 2013, the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the British Virgin Islands signed an intergovernmental agreement (“IGA”) entitled “Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the British Virgin Islands to Improve International Tax Compliance.” The IGA requires, in particular, the exchange of certain information with respect to United Kingdom Reportable Accounts on an automatic basis, pursuant to the provisions of Article 5A of the 2008 Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the British Virgin Islands for the exchange of information relating to tax matters (the “TIEA”).
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • February 5th, 2013
The Competent Authorities of the United States of America and the Kingdom of Norway hereby enter into the following mutual agreement (the “Agreement”) clarifying the meaning of “remuneration described in Article 17 (Governmental Functions)” and “payments described in Article 19 (Social Security Payments)” as those phrases are used in the last sentence of paragraph 6 of Article 24 (Source of Income) of the Convention Between the United States of America and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property, signed on December 3, 1971, and as amended by the Protocol signed on September 19, 1980 (the ”Treaty”). This Agreement is entered into under paragraph 2 of Article 27 (Mutual Agreement Procedure) of the Treaty.
COMPETENT AUTHORITY AGREEMENTCompetent Authority Agreement • May 14th, 2024
The Competent Authorities of Austria and the United States enter into the following agreement (“Agreement”) concerning the interpretation of Articles 20, 21 and 23 of the Convention Between the Republic of Austria and the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Income Taxes, signed May 31, 1996. The Agreement is entered into under Article 24 (Mutual Agreement Procedure). For the purposes of this Agreement, “Article” refers to an Article of the Treaty.
Competent authority agreement between the competent authority of the Republic of Austria and the competent authority of the Republic of Italy concerning the interpretation and application of the Convention between the Republic of Austria and the...Competent Authority Agreement • June 26th, 2020
The competent authority of the Republic of Austria and the competent authority of the Republic of Italy, desiring to minimize the negative tax consequences of the Covid-19 pandemic and in particular the burden of cross-border workers, have concluded the following competent authority agreement according to Article 25 paragraph 3 of the Convention between the Republic of Austria and the Republic of Italy for the avoidance of double taxation and the prevention of tax evasion and avoidance with respect to taxes on income and on capital, signed in Vienna on the 29th June 1981 as amended by the Protocol signed in Vienna on the 25th November 1987 (“the Convention”) with respect to the interpretation and application of Article 15 paragraph 4 of the Convention:
