Partijen en gegevens

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.

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:

Article 2, paragraph 1.b:

Tax on documents transferring title to real property (avgift på dokument som overfører hjemmel til fast eiendom).

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 Norway 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”), Norway 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.

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

Considering that Norway 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, Norway 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.

Annex A - Taxes to which the Convention would apply/Impôts auxquels s'applique la Convention

( Paragraph 2 of Article 2 of the Convention)/( Article 2, paragraphe 2 de la Convention)

Article 2, paragraph[lees: paragraphe] 1(a):

Article 2, paragraphe 1(a):

Article 2, paragraph 1(b):

Article 2, paragraph[lees: paragraphe] 1(b):

Annex B - Competent authorities/Autorités compétentes

(paragraph 1(d) of Article 3 of the Convention/( Article 3, paragraphe 1(d) de la Convention.

Sweden/Suede

The Minister of Finance or the National Tax Board/Le Ministre des Finances ou le Conseil National Fiscal (Riksskatteverket).

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:

Article 2, paragraph 1b:

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;

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;

Sweden 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 Sweden 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.

Sweden declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between Sweden 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.

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 Sweden 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”), Sweden 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.

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.

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.

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):

Article 2, paragraph 1 (b):

Greenlandic taxes :

Article 2, paragraph 1 (a)

Article 2, paragraph 1 (b)

Denmark withdraws its declaration with respect of Faroe Islands made in connection with the ratification of the Convention. It is decided that the Convention will also be applicable in Faroe Islands from 1 January 2007. Annexes A and B to the Convention are accordingly supplemented as follows:

Amendment of Annex A (Taxes Covered)

In Annex A, the following shall be added:

Faroese taxes

Article 2, paragraph 1. a:

Article 2, paragraph 1. b:

In Annex B, the following shall be added:

The Faroe Islands Customs and Tax Administration (Toll- og Skattstova Føroya).

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 Kingdom of Denmark 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 Kingdom of Denmark 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.

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 Kingdom of Denmark, the Faroe Island and Greenland have 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, they have 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 (the Kingdom of Denmark and the Faroe Islands) and in 17 December 2015 (Greenland);

...

For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

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.

Article 30, paragraph 1.e

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

Annex A - Taxes to which the Convention would apply

Article 2, paragraph 1.a.i

Article 2, paragraph 1.a.ii

Article 2, paragraph 1.b.i

Article 2, paragraph 1.b.iii

Under category C:

Under category G:

Article 2, paragraph 1.b.iv

Annex B - Competent Authorities

The Ministry of Economy and Finance - Tax Policy Department.

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:

Article 2, paragraph 1 (b) (iv):

Local Property Tax (Imposta municipale propria - IMU)

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

Considering that Italy has committed to automatically exchange information in/as of 2017 and that, in order to be able to automatically exchange information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters (hereafter the “amended Convention”) in accordance with the timeline to which it has committed, Italy has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 29 October 2014;

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

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

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

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

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

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

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

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

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

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 Italy 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’), Italy 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;

Italy 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 Italy and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction.

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.

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 Finland 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”), Finland 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.

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

Considering that Finland 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, Finland 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.

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.

In accordance with Article 2, paragraph 3, of the Convention, Iceland declares that Annex A to the Convention hasbeen changed as follows:

Annex A - Taxes to which the Convention would apply:

Article 2, paragraph 1.a.i:

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:

Article 2, paragraph 1.b.iv:

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.

Article 3, paragraph 1d

The Minister of Finance and Economic Affairs or the Minister's authorised representative.

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 Iceland 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”), Iceland 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 May 2016;

[...]

For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

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

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

The Kingdom of the Netherlands (for the Netherlands) declares:

The Kingdom of the Netherlands (for the Netherlands Antilles and Aruba) declares:

Annex A

Taxes to which the Convention applies for the Netherlands:

Article 2, paragraph 1 (a)

Article 2, paragraph 1 (b)

Article 2, paragraph 1 (b)

Annex A

Taxes to which the Convention applies for the Netherlands Antilles:

Article 2, paragraph 1 (a)

Annex A

Taxes to which the Convention applies for Aruba:

Article 2, paragraph 1 (a)

Annex B

Competent Authorities for the Netherlands:

Annex B

Competent Authorities for the Netherlands Antilles:

The Minister of Finance or his authorised representative

Annex B

Competent Authorities for Aruba:

The Minister of Finance or his authorised representative

Annex C

Definition of the term ‘national’ for the purpose of the Convention:

The term ‘national’ means for the Netherlands:

Annex C

The term ‘national’ means for the Netherlands Antilles:

Annex C

The term ‘national’ means for Aruba:

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

The Kingdom of the Netherlands will apply the Convention to the Netherlands Antilles and Aruba only in respect of Parties to this Convention with which the Kingdom of the Netherlands has concluded a convention for the avoidance of double taxation which is applicable to the Netherlands Antilles and/or Aruba and which contains a provision concerning exchange of information.

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

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

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

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

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.

Considering that the Netherlands have committed to automatically exchange information in 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”), the Netherlands have signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on October 29, 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 Kingdom of the Netherlands declares, for the European part of the Netherlands and for the Caribbean part of the Netherlands (the islands of Bonaire, Sint Eustatius and Saba), that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between these parts of the Kingdom of the Netherlands 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 Kingdom of the Netherlands declares, for the European part of the Netherlands and for the Caribbean part of the Netherlands (the islands of Bonaire, Sint Eustatius and Saba), that the amended Convention shall also have effect for administrative assistance under its Article 5, between these parts of the Kingdom of the Netherlands 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.

Considering that the Netherlands intend 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 Netherlands have signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on January 27, 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 Kingdom of the Netherlands declares, for the European part of the Netherlands and for the Caribbean part of the Netherlands (the islands of Bonaire, Sint Eustatius and Saba), that the amended Convention shall have effect in accordance with the terms of the CbC MCAA for administrative assistance under the CbC MCAA between these parts of the Kingdom of the Netherlands 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.

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;

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

The Kingdom of the Netherlands declares for Aruba that the amended Convention shall also have effect for administrative assistance under its Article 5, between Aruba and the other Parties to the amended Convention that have made similar declarations, irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, 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.

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;

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 Kingdom of the Netherlands declares for Curaçao that the amended Convention shall have effect in accordance with the terms of the CRS MCAA for administrative assistance under the CRS MCAA between Curaçao 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 Kingdom of the Netherlands declares for Curaçao that the amended Convention shall also have effect for administrative assistance under its Article 5, between Curaçao 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.

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;

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

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

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

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

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

Confirming that the capacity of a jurisdiction to send CbC Reports under Article 6 of the amended Convention and the CbC MCAA shall be governed by the terms of the CbC MCAA, including the relevant reporting periods of the sending jurisdiction contained therein, irrespective of the taxable periods or charges to tax of the receiving jurisdiction to which such information relates;

The Kingdom of the Netherlands declares, for Curaçao, that the amended Convention shall have effect in accordance with the terms of the CbC MCAA for administrative assistance under the CbC MCAA between Curaçao 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.

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.

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.

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

Considering that the Republic of India 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 Republic of India signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 3 June 2015;

...

For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

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 Republic of India 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 Republic of India 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 May 2016;

[...]

For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

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.

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.

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

Considering that Malta 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, Malta 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.

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:

Article 2, paragraph 1.a.ii:

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

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

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

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

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

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.

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

Considering that Ireland has committed to automatically exchange information in 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, Ireland has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 24 October 2014;

[...]

For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

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 Ireland 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”), Ireland has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 17 January 2016;

[...]

For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

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'.

Pursuant to sub-paragraph (b) of paragraph 1 of Article 30 of the Convention, the Republic of Poland will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes. Pursuant to sub-paragraph (d) of paragraph 1 of Article 30 of the Convention, the Republic of Poland will not provide assistance in the service of documents for all taxes.

The Government of Poland withdraws the following reservation made to the Convention on Mutual Administrative Assistance in Tax Matters, done in Strasbourg, on 25 January 1988: ‘Pursuant to sub-paragraph (b) of paragraph 1 of Article 30 of the Convention, the Republic of Poland will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.’ The decision enters into force the day of its signature.

The Government of Poland withdraws the following reservation made to the Convention on Mutual Administrative Assistance in Tax Matters, done in Strasbourg, on 25 January 1988: Pursuant to sub-paragraph (d) of paragraph 1 of Article 30 of the Convention, the Republic of Poland will not provide assistance in the service of documents for all taxes.

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

Considering that the Republic of Poland has committed to automatically exchange information in 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 Republic of Poland 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.

ANNEX A - Taxes to which the Convention would apply

ANNEX B - Competent authorities

Minister for Finance or an authorised representative.

ANNEX C - Definition of the word ‘national’ for the purpose of the Convention

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:

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 Kingdom of Belgium 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 Kingdom of Belgium 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.

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 Kingdom of Belgium 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 Kingdom of Belgium 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.

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:

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.C:

Article 2, paragraph 1. b. iii.D:

Article 2, paragraph 1. b. iii.E:

Article 2, paragraph 1. b. iii.G:

Article 2, paragraph 1. b. iv:

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:

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.

The Republic of Cyprus objects to the declaration of the Republic of Azerbaijan dated 23 may 2014 and registered at the Secretariat General of the OECD on 23 September 2014, 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.

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.

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 application of Article 2 of the Convention, France communicates the list of taxes to which the Convention applies in France, constituting Annex A referred to in Article 2, of the Convention:

Annex A - Tax covered

Article 2, paragraph 1.a.:

Article 2, paragraph 1.b.:

Annex B - Competent authorities

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

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.

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

Considering that France has committed in 2014 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, France has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information in conformity with the Common Reporting Standard (hereafter the “CRS MCAA”) on 29 October 2014;

[...]

For the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.

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.

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.:

Article 2, paragraph 1.b.:

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 thoses taxes in Article 2, paragraph 1, which fall within:

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.

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 Turks and Caicos Islands, for whose international relations the United Kingdom is responsible.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Government of the Turks and Caicos Islands 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, the Government of the Turks and Caicos Islands 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 applies

For the Turks and Caicos Islands, the Convention shall apply to those taxes in Article 2, paragraph 1, which fall within paragraph (iii) of sub-paragraph (b).

Annex B — Competent authorities

The competent authority for the Turks and Caicos Islands shall be the Permanent Secretary for the Ministry of Finance, Investment and Trade or their authorised representative.

Annex C — Definition of a ‘national’ for the purpose of the Convention

In relation to the Turks and Caicos Islands, the term ‘national’ means a person defined as a Turks and Caicos Islander under section 132 of the Turks and Caicos Islands Constitution Order 2011 S.I. 2011/1861.

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 Cayman Islands, for whose international relations the United Kingdom is responsible.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Government of the Cayman Islands 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, the Government of the Cayman Islands 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 applies

For the Cayman Islands, 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

The competent authority for the Cayman Islands shall be the Tax Information Authority or its authorised representative.

Annex C - Definition of the word ‘national’ for the purpose of the Convention

In relation to the Cayman Islands, the term ‘national’ means any person who possesses Caymanian status under the repealed Immigration Law (2003 Revision) or any earlier law providing for the same or similar rights, and includes any person who acquires the status under Part III of the Immigration Law (2012 Revision).

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 Anguilla, for whose international relations the United Kingdom is responsible.

Pursuant to Article 30, paragraph 1(a), of the Convention, the Government of Anguilla will not provide any form of assistance in relation to the taxes of other Parties described in Article 2, paragraphs 1.b(i), (ii), (iii)(A), (iii)(E), (iii)(F), (iii)(G) or (iv), of the Convention.

Pursuant to Article 30, paragraph 1(b), of the Convention, the Government of Anguilla 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 applies

For Anguilla, the Convention shall apply to those taxes in Article 2, paragraph 1, which fall within paragraphs (iii)(B), (iii)(C) or (iii)(D) of sub-paragraph (b).

Annex B - Competent authorities

The competent authority for Anguilla shall be the Permanent Secretary for Finance or their authorised representative.

Annex C - Definition of the word ‘national’ for the purpose of the Convention

In relation to Anguilla, the term ‘national’ ordinarily means any person regarded as belonging to Anguilla under section 80 of the Anguilla Constitution, as amended by the Anguilla Constitution (Amendment) Order 1990 S.I. 1990/587.

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.

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 Gibraltar, for whose international relations the United Kingdom is responsible.

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, where a reservation has been made under Article 30, paragraph 1(a) or (b), of the Convention, is in existence at the date of withdrawal of such a reservation 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.

Revised communication of 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 Gibraltar, for whose international relations the United Kingdom is responsible.

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.

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.

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.

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.

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.

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 United Kingdom has committed to automatically exchange information in 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 United Kingdom has signed a Declaration on joining the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (hereafter the “CRS MCAA”) on 21 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 United Kingdom 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 United Kingdom 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 United Kingdom declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between the United Kingdom 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.

This Declaration has limited territorial application and is made only in respect of the United Kingdom’s metropolitan territory. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and overseas territories is respected.

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 Cayman Islands have committed to automatically exchange information in 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 Cayman Islands have 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.)

This Declaration has limited territorial application and is made only in respect of the Cayman Islands. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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

Considering that Bermuda has committed to automatically exchange information in 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, Bermuda 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. )

Bermuda 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 Bermuda and the other Parties to the amended Convention that have made similar declarations, for tax matters involving intentional conduct which is liable to prosecution under the criminal laws of the receiving jurisdiction irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, and retroactively for tax matters not involving intentional conduct which is liable to prosecution under the criminal laws of the receiving jurisdiction for taxable periods in the receiving jurisdiction beginning on or after 1 January 2015, considering that Bermuda’s effective date of the Amended Convention is 1 January 2015 and the earliest reporting periods of receiving and sending jurisdictions covered by the CRS MCAA is 1 January 2016.

Bermuda declares that the amended Convention shall also have effect for administrative assistance under its Article 5, between Bermuda and the other Parties to the amended Convention that have made similar declarations, 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, for tax matters involving intentional conduct which is liable to prosecution under the criminal laws of the receiving jurisdiction irrespective of the taxable periods or charges to tax to which such information relates in the receiving jurisdiction, and retroactively for matters not involving intentional conduct which is liable to prosecution under the criminal laws of the receiving jurisdiction for taxable periods in the receiving jurisdiction beginning on or after 1 January 2015, considering that Bermuda’s effective date of the Amended Convention is 1 January 2015 and the earliest reporting periods of receiving and sending jurisdictions covered by the CRS MCAA is 1 January 2016.

This Declaration has limited territorial application and is made only in respect of Bermuda. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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 Government of Jersey has committed to automatically exchange information in 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 Government of Jersey 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.)

This Declaration has limited territorial application and is made only in respect of the Bailiwick of Jersey. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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

Considering that Guernsey has committed to automatically exchange information in 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, Guernsey 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.)

This Declaration has limited territorial application and is made only in respect of Guernsey. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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 Isle of Man has committed to automatically exchange information in 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 Isle of Man 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.)

This Declaration has limited territorial application and is made only in respect of the Isle of Man. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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 Guernsey 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”), Guernsey 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 October 2016;

… ( for the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.)

This Declaration has limited territorial application and is made only in respect of Guernsey. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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.

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:

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:

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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.

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 Isle of Man 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 Isle of Man 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 October 2016;

…

( for the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.)

This Declaration has limited territorial application and is made only in respect of the Isle of Man. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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 Jersey 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 Government of Jersey 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 October 2016;

[…] (for the further content of the declaration please refer to the declaration of Germany, mutatis mutandis.)

This Declaration has limited territorial application and is made only in respect of the Bailiwick of Jersey. For the avoidance of doubt, the constitutional relationship between the United Kingdom and the Bailiwick of Jersey is respected.

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 United Kingdom 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 United Kingdom 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.)

This Declaration has limited territorial application and is made only in respect of the United Kingdom’s metropolitan territory. For avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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 Cayman Islands 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 Cayman Islands 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.)

This Declaration has limited territorial application and is made only in respect of the Cayman Islands. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

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 MONTSERRAT 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”), MONTSERRAT has signed a Declaration on joining the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (hereafter the “CbC MCAA”) on 31 MARCH 2023;

[…]

(For the further content of the declaration, please refer to the declaration of Germany, mutatis mutandis.)

[…]

This declaration has limited territorial application and is made only in respect of Montserrat. For the avoidance of doubt, the constitutional relationship between the United Kingdom and its Crown Dependencies and Overseas Territories is respected.

Annex A - Taxes to which the Convention would apply:

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.

Spain declares that it complies with Annexes A, B and C of the Convention as follows :

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 :

Article 2, paragraph 1.b.i.: