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 to address issues of interest to the respective jurisdictions (at the end of this page).

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

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Austria on the Exchange of Country-by-Country Reports PDF

Bahamas

Competent Authority Arrangement Between the 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 of America and the Kingdom of 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

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

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

France

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

Georgia

Competent Authority Arrangement Between the Competent Authorities of the United States of American and Georgia PDF

Germany

Arbitration Board Operating Guidelines PDF

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 the Republic of Germany (PDF) PDF

Gibraltar

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

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

Greenland Competent Authority Arrangement Between the Competent Authorities of the United States of America and Greenland 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 of America and the States of 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 to Improve International Tax Compliance and to Implement FATCA  PDF

Holy See

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Holy See, Acting Also in the Name and on Behalf of the Vatican City State  PDF
(PDF) PDF

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

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

Competent Authority Arrangement Between the Competent Authorities of 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

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

Agreement Between the Competent Authority of the United States of America and the Competent Authority of Ireland to Update Annex II of the Agreement Between the Government of the United States of America and the Government of Ireland to Improve International Tax Compliance and to Implement FATCA PDF

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

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

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

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 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

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Poland 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

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

Serbia Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Serbia 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

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

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

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

Implementing Arrangement Regarding Paragraphs 6 and 7 of Article 25 of the Convention between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income PDF

U.S.-Swiss: References to NAFTA upon entry into force of USMCA. June 25, 2020 PDF

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

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

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

Agreement Between the Competent Authority of the United States of America and the Competent Authority of the United Kingdom of Great Britain and Northern Ireland to update Annex II of the Agreement Between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland to improve International Tax Compliance and Implement FATCA 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 VIET NAM 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