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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.

The Competent Authority Arrangements for purposes of Country-by-Country exchange can be found separately on the Jurisdiction Status Table page.

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)

Anguilla 

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Australia on the Exchange of Country-by-Country Reports (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)

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of Belgium on the Exchange of Country-By-Country Reports (PDF)

Bermuda Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Bermuda on the Exchange of Country-by-Country Reports (PDF)

Brazil

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Federative Republic of Brazil on the Exchange of Country-by-Country Reports (PDF)

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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Canada on the Exchange of Country-By-Country Reports (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)

Arrangement Between the Competent Authority of the United States of America and the Competent  Authority of the Cayman Islands on the Exchange of Country-by-Country Reports (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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Colombia on the Exchange of Country-by- Country Reports (PDF)

Costa Rica

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

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Czech Republic on the Exchange of Country-By-Country Reports (PDF)

Denmark

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of Denmark on the Exchange of Country‐By‐Country Reports (PDF)

Dominican Republic

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

Estonia, Republic of

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Estonia on the Exchange of Country-By Country Reports (PDF)

Finland

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Finland on the Exchange of Country-By-Country Reports (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)

Greece

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Hellenic Republic on the Exchange of Country-By-Country Reports (PDF)

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

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

Guernsey

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Guernsey on the Exchange of Country‐By‐Country Reports (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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Iceland on the Exchange of Country-By Country Reports (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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Ireland on the Exchange of Country-by-Country Reports (PDF)

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Isle of Man on the Exchange of Country-by-Country Reports (PDF)

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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Italy on the Exchange of Country-by-Country Reports (PDF)

Jamaica

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

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)

Jersey Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Jersey on the Exchange of Country-By Country Reports (PDF)
Korea, Republic of 

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

Competent Authority Arrangement Regarding the Interpretation of Article 3 (Fiscal Domicile) of the Income Tax Convention between the United States and Korea (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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Latvia on the Exchange of Country-By-Country Reports (PDF)

Liechtenstein

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

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

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Grand Duchy of Luxembourg on the Exchange of Country-By-Country Reports (PDF)

Malta

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Malta on the Exchange of Country-by-Country Reports (PDF)

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)

 

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the United Mexican States on the Exchange of Country-by-Country Reports (PDF)

 

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

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of 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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of New Zealand on the Exchange of Country‐By‐Country Reports (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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of Norway on the Exchange of Country-By-Country Reports (PDF)

Panama

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

Philippines

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

Poland Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Poland on the Exchange of Country-by-Country Reports (PDF)

Portugal

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Portuguese Republic on the Exchange of Country-By-Country Reports (PDF)

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 Korea  

Romania

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

Saint Kitts and Nevis Competent Authority Arrangement between the Competent Authorities of the United States of America and the Federation of St. Kitts and Nevis (PDF)
Saint Lucia

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

Saudi Arabia

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

Slovak Republic

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Slovak Republic on the Exchange of Country-By-Country Reports (PDF)

Slovenia

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Slovenia on the Exchange of Country-by-Country Reports (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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of Spain on the Exchange of Country-By-Country Reports (PDF)

South Africa

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

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of South Africa on the Exchange of Country-by-Country Reports (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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Sweden on the Exchange of Country-By-Country Reports (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)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the United Kingdom of Great Britain and Northern Ireland on the Exchange of Country-By-Country Reports (PDF)

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