Verdrag inzake wederzijdse administratieve bijstand in belastingzaken

Partij

Ivoorkust toegevoegd

• Ondertekening: 23-04-2025
• Voorbehoud / verklaring: Nee
• Bezwaren: Nee

Partij

Argentinië gewijzigd

• toegevoegd voorbehoud
  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)).

Partij

Filipijnen gewijzigd

• Ratificatie: 07-01-2025 (R)
• In werking: 01-05-2025
• Voorbehoud / verklaring: Ja

• toegevoegd voorbehoud
  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.

Partij

Trinidad en Tobago gewijzigd

• toegevoegd voorbehoud
  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.

Partij

Trinidad en Tobago gewijzigd

• Ratificatie: 03-12-2024 (R)
• In werking: 01-04-2025

Partij

Trinidad en Tobago gewijzigd

• Ondertekening: 07-11-2024
• Voorbehoud / verklaring: Ja
• Bezwaren: Nee

• toegevoegd voorbehoud
  07-11-2024
  Annex B – Competent authority The Minister of Finance or his authorised representative.

Partij

Algerije toegevoegd

• Ondertekening: 10-10-2024
• Voorbehoud / verklaring: Nee
• Bezwaren: Nee

Partij

Indonesië gewijzigd

• toegevoegd voorbehoud
  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.

Partij

Papoea-Nieuw-Guinea gewijzigd

• Ratificatie: 31-08-2023 (R)
• In werking: 01-12-2023

• toegevoegd voorbehoud
  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.

Thailand gewijzigd

• toegevoegd voorbehoud
  14-09-2023
  Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information. Considering that Thailand has committed to automatically exchange information in/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, Thailand has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 28 March 2022; […] (For the further content of the declaration, please refer to the declaration of Germany, mutatis mutandis.)

Vietnam gewijzigd

• Ratificatie: 31-08-2023 (R)
• In werking: 01-12-2023

• toegevoegd voorbehoud
  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.

Partij

Papoea-Nieuw-Guinea gewijzigd

• Voorbehoud / verklaring: Ja

• toegevoegd voorbehoud
  20-07-2023
  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 the Independent State of Papua New Guinea intends to start automatically exchanging Country by Country 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 Independent State of Papua New Guinea has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 14 March 2023; [...] (For the further content of the declaration, please refer to the declaration of Germany, mutatis mutandis.)