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Competent Authority Arrangements

A Competent Authority Arrangement is a bilateral agreement between the United States and the treaty partner to clarify or interpret treaty provisions. Competent Authority Arrangements also exist between the United States Internal Revenue Service and each United States Territory and Commonwealth tax agency and addresses issues of interest to the respective jurisdictions.

Country Arrangement

Algeria

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the People’s Democratic Republic of Algeria (PDF)

Antigua and Barbuda

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Government of Antigua and Barbuda (PDF)

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)

Bahamas

Competent Authorities of the United States of America and the Commonwealth of the Bahamas (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)

Brazil

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Government of the Federative Republic of Brazil (PDF)

British Virgin Islands

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Government of the British Virgin Islands (PDF)

Bulgaria

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

Cambodia

Competent Authority Arrangement Between the Competent Authorities of The United States of America and the Royal Government of Cambodia (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)

Colombia

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

Costa Rica

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

Curacao

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of the Netherlands, in Respect of Curacao (PDF)

Cyprus

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

French Republic

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

Georgia

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

Guernsey

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

Guyana

Competent Authority Arrangement Between the Competent Authorities of The United States of America and the Government of the Co-Operative Republic of Guyana (PDF)

Holy See

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

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

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)

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

Italy

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

Kosovo

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

Kuwait Competent Authority Arrangement Between the Competent Authorities of The United States of America and the  State of Kuwait (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)

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Kingdom of the Netherlands on the Exchange of Country-by-Country Reports (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)

Competent Authority Arrangement between the Competent Authorities of the United States of America and Norway on the Exchange of Country-by-Country Reports (PDF)

Philippines

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

Portugal

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

Qatar

Competent Authority Arrangement Between the Competent Authorities of The United States of America and the  State of Qatar (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)

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

Slovak Republic

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

St. Vincent and the Grenadines

Competent Authority Arrangement Between the Competent Authorities of the United States of America and St. Vincent and the Grenadines (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)

Turkey

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

Turks and Caicos Islands

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

United Arab Emirates

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

Vietnam

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

 

Territory Arrangement
American Samoa Tax Implementation Agreement between the United States of America and American Samoa (PDF)
Guam Agreement on Coordination of Tax Administration - Department of Revenue and Taxation of Guam and the United States - Internal Revenue Service (PDF)
Northern Mariana Islands Tax Coordination Agreement between the United States of America and the Commonwealth of the Northern Mariana Islands (PDF)
Puerto Rico Tax Coordination Agreement between the United States of America and the Commonwealth of Puerto Rico (PDF)
U.S. Virgin Islands Tax Implementation Agreement between the United States of America and the Virgin Islands (PDF)

 

References/Related Topics

Page Last Reviewed or Updated: 22-May-2017