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Competent Authority Agreements

A Competent Authority Agreement is a bilateral agreement between the United States and the treaty partner to clarify or interpret treaty provisions.

Country Agreement
Austria U.S. - Austria: Tax Treatment of Certain Scholarships. March 1, 2005 (PDF)

U.S. - Austria : Taxing Deferred Payments to U.S. Citizens Residing in Austria. August 27, 2003 (PDF)
Belgium

Announcement Concerning Mutual Agreement Procedure Arbitration under the Recent Income Tax Treaty Between the United States and Belgium

Memorandum of Understanding Between the U.S. and Belgium-2009

Arbitration Board Guidelines-2009

US-Belgium Limitation on Benefits - Equivalent Beneficiary. October 15, 2009 (PDF)

US-Belgium Agreement identifying Pensions for Treaty benefits. April 9, 2010 (PDF)

US-Belgium Tax Treatment of Fellowships. July 14, 2010 (PDF)

U.S.-Belgium Agreement Regarding Taxes Imposed by Belgian Municipalities - May 2011

Belgium Competent Authority Agreement - Profit Attribution - 7-16-13 (PDF)

Canada

Memorandum of Understanding Between the Competent Authorities of Canada and The United States of America (PDF)

Arbitration Board Operating Guidelines (PDF)

China US - China MAP agreement Treaty Article 19-Professors and Teachers. November 24, 2010 (PDF)
Germany

Arbitration Board Operating Guidelines

Memorandum of Understanding between the U.S. and Germany

US-Germany Agreement on Pensions - signed March 19, 2012 (PDF)

U.S. - Germany Mutual Agreement Regarding Taxation of Certain Consular Employees October 1, 2009 (PDF)

India U.S. - India: Memorandum Of Understanding Regarding Deferment Of Assessment And/Or Suspension Of Collection Of Taxes During Mutual Agreement Procedure. September 25, 2002 (PDF)
Ireland U.S. - Ireland: Competent Authority Agreement regarding the income received by Irish unit holders in a Common Contractual Fund - February 9, 2006. (PDF)
Japan

U.S. - Japan: Guidance regarding the Commencement of Application of the new Tax Convention between the United States and Japan. June 23, 2004 (PDF)

U.S. - Japan: The Competent Authorities of the United States and Japan Agree to the following Guidelines concerning the meaning of the term Investment Bank. December 27, 2005 (PDF)

U.S. - Japan: Memorandum of Understanding - First Publication Concerning Notification of Self-Certification of U.S. and Japanese Resident Investment Banks. March 3, 2006 (PDF)

Luxembourg U.S. – Luxembourg: Interpretation of Tax Treaty’s Transition Rules. November 09, 2001 (PDF)
Mexico

U.S. - Mexico: Mutual Agreement Regarding Eligibility of Fiscally Transparent Entities to Benefits. August 26, 2005 (PDF)

U.S. - Mexico: Mutual Agreement Regarding Eligibility of Fiscally Transparent Entities to Benefits. December 22, 2005 (PDF)

Netherlands

U.S. - Netherlands Agreement Regarding Dutch Limited Funds for Mutual Account - May 21, 2012 (PDF)

U.S. - Netherlands: Updated Agreement Identifying Pensions for Treaty Benefits August 13, 2007 (PDF)

U.S. - Netherlands: Administrative Arrangements for Mutual Agreement Procedure. October 7, 2003 (PDF)

U.S. - Netherlands: Pensions Investing Through Hybrid entities. March 21, 2003 (PDF)

U.S. - Netherlands - Pensions Agreement modified to eliminate Dutch "Qualification" Certification. March 30, 2010 (PDF)

New Zealand U.S. - New Zealand: Mutual Agreement Regarding Treatment of Income Derived Through Certain Fiscally Transparent Entities. February 10, 2005 (PDF)
Norway

U.S. - Norway - Agreement Regarding Offshore Activities - February 2013 (PDF)

U.S. - Norway - Eligibility of Fiscally Transparent Entities for Treaty Benefits - January 2013 (PDF)

U.S. - Norway - Source of Remuneration for Government Services and Social Security Payments - December 2012 (PDF)

Spain U.S.- Spain Agreement Regarding Eligibility of Benefits to Fiscally Transparent Entities. February 15, 2006 (PDF)
Switzerland

U.S. - Swiss: Pension Plans for Tax Treaty Benefits. December 10, 2004 (PDF)

US - Swiss: Guidance on Treaty Benefits. August 22, 2003 (PDF)

United  Kingdom

U.S. - U.K. agreement defining the term "First Notification" under Treaty Article 26(1) - September 12, 2007 (PDF)

U.S. - U.K. Agreement Regarding Dual Consolidated Loss Rules. October 6, 2006 (PDF)

U.S. - U.K.: Agreement Identifies U.K. Pension Arrangements for Tax Treaty Benefits. April 13, 2005 (PDF)

U.S. - U.K.: New Administrative Arrangements for Mutual Agreement Procedure. November 13, 2000 (PDF)

References/Related Topics

Page Last Reviewed or Updated: 10-Dec-2013