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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

Australia

Competent Authority Arrangement Between the Competent Authorities of The United States of America and Australia (PDF)

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)

Barbados

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Barbados (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)

Competent Authority Arrangement between the Competent Authorities of the United States and Belgium (PDF)

Canada

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

Arbitration Board Operating Guidelines (PDF)

Cayman Islands

Competent Authority Arrangement Between the Competent Authorities of the Cayman Islands and the United States of America (PDF)

China

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

Czech Republic

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Czech Republic (PDF)

Denmark

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Kingdom of Denmark (PDF)

Finland

Competent Authorities of the United States of America and Republic of Finland (PDF)

Germany

Arbitration Board Operating Guidelines

Memorandum of Understanding between the U.S. and Germany

US-Germany Agreement on Pensions - signed March 19, 2012

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

Competent Authority Arrangement between the Competent Authorities of the United States of America and Germany (PDF)

Gibraltar

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Gibraltar

Guernsey

Competent Authority Arrangement between the Competent Authorities of the United States and Guernsey

Hungary

Competent Authority Arrangement between the United States of America and Hungary (PDF)

Iceland

Competent Authority Arrangement between the Competent Authorities of the United States of America and Iceland (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)

Competent Authority Arrangement Between the Competent Authorities of The United States of America and The Republic of India (PDF)

Ireland

Competent Authority Arrangement between the Competent Authorities of the United States of America and Ireland (PDF)

U.S. - Ireland: Competent Authority Agreement regarding the income received by Irish unit holders in a Common Contractual Fund - February 9, 2006.

Isle of Man

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Isle of Man (PDF)

Jamaica

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Jamaica (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)

Latvia

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Latvia (PDF)

Liechtenstein

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Principality of Liechtenstein (PDF)

Luxembourg

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

Competent Authority Arrangement between the Competent Authorities of  the United States of America and the Grand Duchy of Luxembourg (PDF)

Malta

Competent Authority Arrangement between the Competent Authorities of  the United States of America and Republic of Malta (PDF)

Mauritius

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Mauritius (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)

Competent Authority Arrangement between the Competent Authorities of the Department of the Treasury of the United States of America and the Ministry of Finance and Public Credit of the United Mexican States (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)

Competent Authority Arrangement between the Competent Authorities of the United States and Netherlands (PDF)

New Zealand

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

Competent Authority Arrangement between the Competent Authorities of the United States of America and New Zealand (PDF)

U.S. - New Zealand Competent Authority Arrangement Regarding Meaning of the Term “Resident in New Zealand” under the IGA for a Financial Institution that is a Trust (other than a Unit Trust) (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)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of Norway (PDF)

Republic of Estonia

Competent Authority Arrangement between the United States of America and the Republic of Estonia (PDF)

Romania

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Romania (PDF)

Slovenia

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Slovenia (PDF)

Spain

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

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of Spain (PDF)

South Africa

Competent Authority Arrangement between the Competent Authorities of  the United States of America and the Republic of South Africa (PDF)

Sweden

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Sweden (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)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and United Kingdom of Great Britain and Northern Ireland (PDF)

References/Related Topics

Page Last Reviewed or Updated: 01-Feb-2016