Статус Конвенции о взаимной административной помощи по налоговым делам (ETS № 127) (Страсбург, 25 января 1988 года) [рус., англ.]

СПИСОК ПОДПИСАНИЙ И РАТИФИКАЦИЙ

Примечания. a — присоединение; s — подписание без оговорок о ратификации; su — правопреемство; r — подписание «ad referendum».

R — оговорки; D — заявления, денонсации, частичные отмены; A — государственные органы; T — территориальное применение; C — уведомление; O — возражения.

CHART OF SIGNATURES AND RATIFICATIONS OF TREATY 127

D.

01.10.2004

D.

D. A.

D. A.

Denmark

16.07.1992

16.07.1992

01.04.1995 62

D. A. T.

A.

D. A.

D. A. T.

Georgia

12.10.2010

28.02.2011

Italy

A.

A.

D. A.

D. A.

Luxembourg

A.

Malta

A.

Monaco

A.

Montenegro

A.

Netherlands

A.

North Macedonia

A.

Portugal

27.05.2010

17.11.2014

01.03.2015 62 R. D. A.

Republic of Moldova

62

D. A.

A.

A.

A.

A.

Non-Members of Council of Europe

Notes

a: Accession s: Signature without reservation as to ratification su: Succession r: Signature «ad referendum».

R.: Reservations D.: Declarations, Denunciations, Derogations A.: Authorities T.: Territorial Application C.: Communication O.: Objection.

61: State Signatory to the Convention as amended by the 2010 Protocol.

62: State Party to the Convention as amended by the 2010 Protocol.

RESERVATIONS AND DECLARATIONS FOR TREATY No. 127

CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS

Declarations in force as of today Status as of: 29.10.2026

Organisation for Economic Co-operation and Development

Communication transmitted by the Director General of Legal Affairs of the OECD by a letter dated 7 February 2007 and registered by the Secretariat General on 12 February 2007 — Or. Engl./Fr.

OPINION BY THE CO-ORDINATING BODY OF THE JOINT COUNCIL OF EUROPE/OECD CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS ON THE USE OF THE TERMS «PARTIES» AND «STATES» IN CERTAIN ARTICLES OF THE CONVENTION

I. The use of terms «Parties», «States» and «competent authorities» in the Convention

1. In the Joint Council of Europe/OECD Convention on Mutual Administrative Assistance in Tax Matters, the use of the terms «Parties», «States» or «competent authorities» has been found not to be always consistent, in particular with regard to the authority to enter into agreements for the implementation of the Convention.

II. Opinion of the Co-ordination Body of the Convention

2. Under international law, a treaty shall be interpreted taking into account «any subsequent agreement between the parties regarding the interpretation of the treaty of the application of its provisions» (article 31.3.a of the Vienna Convention on the Law of Treaties). According to paragraph 4 of Article 24 of the Convention on Mutual Administative Assistance in Tax Matters, the Co-ordinating Body (composed of representatives of the competent authorities of the Parties) which monitors the implementation and development of this Convention, under the aegis of OECD, can furnish opinions «on the interpretation of the provisions of the Convention».

3. Given that in certain articles of the Convention the use of the terms «Parties» and «States» may raise issues of interpretation, the following opinion, which as been agreed by the Co-ordinating Body of the Convention, after having consulted with the OECD Secretariat, and particularly with the Directorate of Legal Affairs, will dispel ambiguity and will clarify the interpretation of these articles:

In accordance with paragraph 4 of article 24 of the Convention, the Co-ordinating Body agrees to the following opinion on the interpretation of the Convention:

When the text of the Convention uses, in particular in paragraph 2 of Article 4; paragraph 2 of Article 11; paragraph 2 of Article 22; and Articles 25 and 26, the terms «Parties» or «States» in relation to agreements concluded for the implementation of the Convetnion, these two terms are to be understood to refer to the «competent authorities», as defined in paragraph 1, subparagraph d, of Article 3.

Period covered: 12/02/2007 -

Articles concerned: 24

Albania

Reservations contained in the instrument of ratification deposited with the Secretary General of the OECD on 8 August 2013 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Albania reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b:

iii. Taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

A. estate, inheritance or gift taxes,

B. taxes on immovable property,

F. taxes on the use or ownership of movable property other than motor vehicles.

iv. Taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

In accordance with Article 30, paragraph 1.b, of the Convention, the Republic of Albania reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for taxes described in Article 2, paragraph 1.b, of the Convention.

In accordance with Article 30, paragraph 1.d, of the Convention, the Republic of Albania reserves the right not to provide assistance in the service of documents for the taxes described in Article 2, paragraph 1.b, of the Convention.

In accordance with Article 30, paragraph 1.e, of the Convention, the Republic of Albania reserves the right not to permit the service of documents through the post as provided in Article 17, paragraph 3, with respect to the taxes described in Article 2, paragraph 1.b, of the Convention.

Period covered: 01/12/2013 -

Articles concerned: 30, 2

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 8 August 2013 — Or. Engl.

ANNEX B — Competent Authorities

the Republic of Albania declares that the competent authority, with the powers mentioned in Article 3, paragraph 1.d., of the Convention, is the Ministry of Finance: General Tax Directory.

Period covered: 01/12/2013 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 8 August 2013 — Or. Engl.

ANNEX A — Existing taxes to which the Convention shall apply:

Article 2, paragraph 1.a.i:

• Personal Income Tax (Tatimi mbi te Ardhurat Personale)

Article 2, paragraph 1.a.ii:

• Corporate Income Tax (Tatim Fitimi)

Article 2, paragraph 1.b.i:

• Local Tax on Small Business (Taska Vendore mbi Biznesin e Vogel)

Article 2, paragraph 1.b.ii:

• Social Security Contributions (Kontributet e Sigurimeve Shoqerore)

Article 2, paragraph 1.b.iii.C:

• Value Added Tax (Tatimi mbi Vleren e Shtuar)

Article 2, paragraph 1.b.iii.D:

• Excise Duties (Akciza)

Article 2, paragraph 1.b.iii.E:

• Annual Tax on used motor Vehicles (Taska vjetore e mjeteve të përdorura )

Article 2, paragraph 1.b.iii.G:

• Local Tax on Real Estate (Tatimet mbi Pasurine e Paluajtshme)

Period covered: 1/12/2013 -

Articles concerned: 2

Andorra

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 25 August 2016 — Or. Fr.

In accordance with Article 9, paragraph 3, of the Convention, the Principality of Andorra declares that it will, as a general rule, not accept requests to allow representatives of the competent authority of the applicant State to be present at the appropriate part of a tax examination in the Principality of Andorra.

Period covered: 01/12/2016 -

Articles concerned: 9

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 25 August 2016 — Or. Fr.

In accordance with Article 4, paragraph 3, of the Convention, the Principality of Andorra may inform the persons concerned before transmitting information to a Party pursuant to Articles 5 and 7 of the Convention.

Period covered: 01/12/2016 -

Articles concerned: 4

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 25 August 2016 — Or. Fr.

In accordance with Article 30, paragraph 1.a, of the Convention, the Principality of Andorra will not provide any form of administrative assistance in relation to the taxes of other Parties referred to in Article 2, paragraph 1.b, of the Convention.

In accordance with Article 30, paragraph 1.b, of the Convention, the Principality of Andorra will not provide any form of administrative assistance in the recovery of tax claims, or in the recovery of administrative fines, for all taxes listed in Article 2, paragraph 1, of the Convention.

In accordance with Article 30, paragraph 1.c, of the Convention, the Principality of Andorra will not provide assistance in respect of any tax claim which was in existence at the date of entry into force of the Convention in respect of the Principality of Andorra.

The Principality of Andorra will not provide assistance in respect of any tax claim which was in existence at the date of withdrawal of a reservation made under Article 30, paragraphs 1.a or 1.b, of the Convention.

In accordance with Article 30, paragraph 1.d, of the Convention, the Principality of Andorra will not provide assistance in the service of documents for all taxes listed in Article 2, paragraph 1, of the Convention.

In accordance with Article 30, paragraph 1.f, of the Convention, the Principality of Andorra declares that, for tax matters involving intentional conduct which is liable to prosecution under the criminal laws of the applicant Party the provisions of this Convention shall apply for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Principality of Andorra, or, where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Principality of Andorra.

Period covered: 01/12/2016 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 25 August 2016 — Or. Fr.

ANNEX B — Competent authorities

In Andorra, the term «competent authority» means the Minister of Finance or his authorised representative.

Period covered: 01/12/2016 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 25 August 2016 — Or. Fr.

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i — Taxes on income or profits

• Corporation tax;
• Tax on income of individuals;
• Income tax of economic activities;
• Income tax on income of non-residents in Andorra

Article 2, paragraph 1.a.ii — Taxes on capital gains which are imposed separately from the tax on income or profits

• Tax on capital gain on real estate capital transfer.

Article 2, paragraph 1.a.iii — Taxes on net wealth

• None

Period covered: 01/12/2016 -

Articles concerned: 2

Antigua and Barbuda

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 16 October 2018 — Or. Engl.

Antigua and Barbuda ratifies the Convention with the following declaration:

ANNEX B — Competent authorities

The Commissioner of the Inland Revenue Department or his authorised representative.

Period covered: 01/02/2019 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 16 October 2018 — Or. Engl.

ANNEX C — Definition of the word «national» for the purpose of the Convention

The term «national» in relation to Antigua and Barbuda means:

i. all individuals possessing the nationality of Antigua and Barbuda, and

ii. all legal persons, partnerships, associations and other entities deriving their status as such from the laws in force in Antigua and Barbuda.

Period covered: 01/02/2019 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 16 October 2018 — Or. Engl.

Antigua and Barbuda ratifies the Convention with the following declaration:

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 01/02/2019 -

Articles concerned: 28

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 16 October 2018 — Or. Engl.

Antigua and Barbuda ratifies the Convention with the following declaration:

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i: Income Tax.

Article 2, paragraph 1.a.ii: None.

Article 2, paragraph 1.a.iii: Income Tax.

Article 2, paragraph 1.b.i: Income Tax

Article 2, paragraph 1.b.ii: Social Security Tax.

Article 2, paragraph 1.b.iii.A: Stamp Duty.

Article 2, paragraph 1.b.iii.B: Property Tax.

Article 2, paragraph 1.b.iii.C: Antigua and Barbuda Sales Tax.

Article 2, paragraph 1.b.iii.D: Customs Tax.

Article 2, paragraph 1.b.iii.E: Transport Board Tax.

Article 2, paragraph 1.b.iii.F: Property Tax.

Article 2, paragraph 1.b.iii.G: None.

Period covered: 01/02/2019 -

Articles concerned: 2

Argentina

Declaration transmitted by the Embassy of the Argentine Republic in France to the Secretariat General of the OECD on 31 October 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 31/10/2018 -

Articles concerned: 28

Declaration transmitted by the Embassy of the Argentine Republic in France to the Secretariat General of the OECD on 4 October 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 04/10/2018 -

Articles concerned: 28

Reservation contained in the instrument of ratification deposited with the Secretary General of OECD on 13 September 2012 — Or. Engl.

The Argentine Republic shall not provide any type of assistance in relation to the taxes of the other Parties as mentioned in Article 2, paragraph 1, sub-paragraphs b.i or b.iv, of the Convention according to Article 30, paragraph 1.a, of the Convention.

Period covered: 01/01/2013 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of OECD on 13 September 2012 — Or. Engl.

The Argentine Republic shall not provide assistance in the collection of tax claims or in the collection of administrative fines, for all the taxes, according to the provisions of Articles 11 and 12 of the Convention.

Period covered: 01/01/2013 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of OECD on 13 September 2012 — Or. Engl.

The Argentine Republic shall not provide assistance for the notification and the transfer of documents for any tax, according to the provisions of Article 17 of the Convention.

Period covered: 01/01/2013 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of OECD on 13 September 2012 — Or. Engl.

ANNEX B — Competent Authorities

The Argentine Republic declares that the competent authority, with the powers mentioned in Article 3, paragraph 1.d, of the Convention, is the Federal Administration of Public Revenue.

Period covered: 01/01/2013 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of OECD on 13 September 2012 — Or. Engl.

Argentina ratifies the Convention with the following declaration:

ANNEX A — Taxes to which the Convention would apply:

Article 2, paragraph 1.a.i: Income Tax.

Article 2, paragraph 1.b.ii: Contributions to Social Security.

Article 2, paragraph 1.b.iii. A: Tax on Personal Property.

Article 2, paragraph 1.b.iii. C: Value Added Tax.

Article 2, paragraph 1.b.iii. D:

Tax on Liquid Fuels,

Domestic Tax, Law 24764,

Tax on Insurance and other Assets, Law 3764.

Article 2, paragraph 1.b.iii. G:

Presumptive Income Tax,

Real Property Transfer Tax,

Tax on the Debits and Credits originated from Financial Transactions, Law 25413,

Simpified Regime for Taxpayers (Monotributo).

Period covered: 01/01/2013 -

Articles concerned: 2

Armenia

Declaration contained in the instrument of ratification deposited with the Secretary General of the Council of Europe on 6 February 2020 — Or. Engl.

ANNEX B — Competent Authorities:

State Revenue Committee or its authorised representative.

Period covered: 01/06/2020 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the Council of Europe on 6 February 2020 — Or. Engl.

ANNEX A — Taxes to which the Convention would apply:

Article 2, paragraph 1.a.i:

• Income Tax, Profit Tax

Article 2, paragraph 1.b.iii.C:

• Value-Added Tax

Article 2, paragraph 1.b.iii.D:

• Excise Tax

Article 2, paragraph 1.b.iii.G:

• Turnover Tax, Environmental Tax, Road Tax

Period covered: 01/06/2020 -

Articles concerned: 2

Objection contained in the instrument of ratification deposited with the Secretary General of the Council of Europe on 6 February 2020 — Or. Engl.

The Republic of Armenia objects to the declaration of the Republic of Azerbaijan dated 23 May 2014, registered at the Secretariat General of the OECD on 23 September 2014 and confirmed at the time of ratification of the Protocol on 29 May 2015, and to the declaration of the Republic of Turkey dated 19 October 2011, handed over to the Secretary General of the OECD on 3 November 2011 and confirmed in the instrument of ratification deposited with the Secretary General of the OECD on 26 March 2018, both limiting the implementation of the provisions of the Convention and Protocol only to the States with which the Republic of Azerbaijan and the Republic of Turkey have diplomatic relations.

The aforementioned declarations, which attempt to modify or limit the rights and obligations under the Convention, constitute, in fact, reservations and neither fall under the scope or Article 30 of the Convention, nor are compatible with the object and purpose of the Convention to establish a framework for the cooperation between the member States of the Council of Europe, therefore, as such shall be considered null and void.

Until the withdrawal of the aforementioned reservations, the Republic of Armenia declares that it will be unable to ensure the application of the Convention and Protocol in respect of the Republic of Azerbaijan and the Republic of Turkey.

Period covered: 01/06/2020 -

Articles concerned: -

Declaration contained in the instrument of ratification deposited with the Secretary General of the Council of Europe on 6 February 2020 — Or. Engl.

The Declaration of the Republic of Azerbaijan contained in the instrument of ratification deposited on 3 June 2004, includes unsubstantiated and baseless allegations against the Republic of Armenia and distorts the essence of the Nagorno-Karabakh conflict which was triggered and sustained by the use of force by Azerbaijan against peaceful demands of the people of Nagorno-Karabakh (Republic of Artsakh) for human rights and self-determination.

Period covered: 01/06/2020 -

Articles concerned: -

Australia

Declaration transmitted by a Note verbale from the Permanent Delegation of Australia to the OECD, dated 2 November 2017, registered at the Secretariat General of the OECD on 3 November 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 03/11/2017 -

Articles concerned: 28

Declaration transmitted by a Note verbale from the Permanent Delegation of Australia to the OECD, dated 2 November 2017, registered at the Secretariat General of the OECD on 3 November 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 03/11/2017 -

Articles concerned: 28

Declaration transmitted by the Australian Permanent Delegation to the OECD at the time of deposit of the instrument of ratification with the Secretary General of OECD on 30 August 2012 — Or. Engl.

Annex C — Definition of the term «national» for the purpose of the Convention

In relation to Australia, the term «national» means any individual possessing the citizenship of Australia; and any legal person, company, partnership or association deriving its status as such from the laws in force in Australia.

Period covered: 01/12/2012 -

Articles concerned: 3

Declaration transmitted by the Australian Permanent Delegation to the OECD at the time of deposit of the instrument of ratification with the Secretary General of OECD on 30 August 2012 — Or. Engl.

Annex B — Competent authorities

In relation to Australia, the term «competent authority» means the Commissioner of Taxation or an authorised representative of the Commissioner.

Period covered: 01/12/2012 -

Articles concerned: 3

Declaration transmitted by the Australian Permanent Delegation to the OECD at the time of deposit of the instrument of ratification with the Secretary General of OECD on 30 August 2012 — Or. Engl.

Article 29 — Territorial application of the Convention

Pursuant to Article 29, paragraph 1, of the Convention, Australia declares that with respect to Australia, the Convention shall apply to Australia, excluding all external territories other than:

(i) the Territory of Norfolk Island;

(ii) the Territory of Christmas Island;

(iii) the Territory of Cocos (Keeling) Islands;

(iv) the Territory of Ashmore and Cartier Islands;

(v) the Territory of Heard Island and McDonald Islands; and

(vi) the Coral Sea Islands Territory,

but including any area adjacent to the territorial limits of Australia (including the Territories specified in this Declaration) in respect of which there is for the time being in force, consistently with international law, a law of Australia dealing with the exploration for or exploitation of any of the natural ressources of the exclusive economic zone or the seabed or subsoil of the continental shelf.

Period covered: 01/12/2012 -

Articles concerned: 29

Declaration transmitted by the Australian Permanent Delegation to the OECD at the time of deposit of the instrument of ratification with the Secretary General of OECD on 30 August 2012 — Or. Engl.

Annex A — Taxes to which the Convention applies

For Australia, the Convention shall apply to taxes of every kind and description imposed under the federal laws of Australia administered by the Commissioner of Taxation which correspond to the taxes in the categories referred to in paragraphs 1(a) and (b)(ii) and (iii) of Article 2 of the Convention.

Period covered: 01/12/2012 -

Articles concerned: 2

Austria

Declarations transmitted by a Note Verbale from the Permanent Representation of Austria to the Council of Europe to the Secretariat General of the Council of Europe on 15 November 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 15/11/2018 -

Articles concerned: 28

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 28 August 2014 — Or. Engl.

Pursuant to paragraph 1.a of Article 30 of the Convention, the Republic of Austria reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in sub-paragraph b of paragraph 1 of Article 2:

i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

ii. compulsory social security contributions payable to general government or social security institutions established under public law;

iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

A. estate, inheritance or gift taxes,

B. taxes on immovable property,

D. specific taxes on goods and services such as excise taxes,

E. taxes on the use or ownership of motor vehicles,

F. taxes on the use or ownership of movables property other than motor vehicles,

G. any other taxes;

iv. taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

Period covered: 01/12/2014 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 28 August 2014 — Or. Engl.

Pursuant to paragraph 1.b of Article 30 of the Convention, the Republic of Austria reserves the right not to provide assistance in the recovery of any tax claim or in the recovery of an administrative fine, for all taxes listed in paragraph 1 of Article 2 of the Convention.

Period covered: 01/12/2014 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 28 August 2014 — Or. Engl.

Pursuant to paragraph 1.c of Article 30 of the Convention, the Republic of Austria reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of the Republic of Austria.

Period covered: 01/12/2014 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 28 August 2014 — Or. Engl.

Pursuant to paragraph 1.d of Article 30 of the Convention, the Republic of Austria reserves the right not to provide assistance in the service of documents for the taxes listed in the reservation made pursuant to paragraph 1.a of Article 30 of the Convention.

Period covered: 01/12/2014 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 28 August 2014 — Or. Engl.

Pursuant to paragraph 1.f of Article 30 of the Convention, the Republic of Austria reserves the right not to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

Period covered: 01/12/2014 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 28 August 2014 — Or. Engl.

ANNEX B — Competent Authorities

In relation to the Republic of Austria, the term «competent authority» means the Federal Minister for Finance or his authorised representative.

Period covered: 01/12/2014 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 28 August 2014 — Or. Engl.

ANNEX A — Existing taxes to which the Convention shall apply

Article 2, paragraph 1.a.i

• income tax (Einkommensteuer)
• corporation tax ( Körperschaftsteuer )

Article 2, paragraph 1b.iii. C

• value-added tax (Umsatzsteuer).

Period covered: 01/12/2014

Articles concerned: 2

Azerbaijan

Declaration transmitted by the Embassy of the Republic of Azerbaijan in France to the Secretariat General of the OECD on 24 May 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 24/05/2018

Articles concerned: 28

Declaration contained in a Declaration from the Ministry of Taxes of the Republic of Azerbaijan, dated 23 May 2014, registered at the Secretariat General of the OECD on 23 September 2014 — Or. Engl. and confirmed at the time of the ratification of the Protocol, on 29 May 2015.

Pursuant to Article 4, paragraph 3, of the Convention on Mutual Administrative Assistance in Tax Matters, according to the national legislation of the Republic of Azerbaijan, its competent authorities may inform its resident or national before transmitting information concerning him, in conformity with Article 5 and Article 7 of the Convention.

Period covered: 01/09/2015

Articles concerned: 7, 5

Declaration contained in a Declaration from the Ministry of Taxes of the Republic of Azerbaijan, dated 23 May 2014, registered at the Secretariat General of the OECD on 23 September 2014 — Or. Engl. and confirmed at the time of the ratification of the Protocol on 29 May 2015.

The Republic of Azerbaijan will apply the provisions of the Convention and the Protocol only in respect of the States Parties with which the Republic of Azerbaijan has diplomatic relations.

Period covered: 01/09/2015 -

Articles concerned: -

Declaration contained in the instrument of ratification deposited on 3 June 2004 — Or. Engl.

ANNEX C — Definition of the term «national» is given in the following:

The term «national» means:

. all individuals possessing the nationality of the Republic of Azerbaijan;

. all legal persons (including partnership and joint venture), companies, associations and other organisations deriving their status as such from the legislation of the Republic of Azerbaijan.

Period covered: 01/10/2004

Articles concerned: 3

Declaration contained in the instrument of ratification deposited on 3 June 2004 — Or. Engl.

ANNEX B — Competent authorities:

Ministry of taxes, State Customs Committee, Ministry of Labour and Social Protection of Population, Ministry of Finance.

Period covered: 01/10/2004

Articles concerned: 3

Declaration contained in the instrument of ratification deposited on 3 June 2004 — Or. Engl.

ANNEX A — Taxes to which the Convention would apply:

Article 2, paragraph 1. a. i:

. Income tax from individuals;

. Profit tax from legal persons (with the exception of entities and enterprises that are the property of municipalities);

. Tax whitheld at the source of payment on income of non-residents;

. Tax withheld from the net profit of a permanent establishment.

Article 2, paragraph 1. b. i:

. Profit tax from entities and enterprises that are the property of municipalities.

Article 2, paragraph 1. b. ii:

. Payments to the State Social Protection Fund.

Article 2, paragraph 1. b. iii.A:

. Property tax from legal persons.

Article 2, paragraph 1. b. iii.B:

. Land tax from legal persons.

Article 2, paragraph 1. b. iii.C:

. Value added tax.

Article 2, paragraph 1. b. iii.D:

. Excise tax.

Article 2, paragraph 1. b. iii.E:

. Road tax.

Article 2, paragraph 1. b. iii.G:

. Mining tax;

. Tax under simplified system;

. Duties withheld according to the «Law of state duties».

Article 2, paragraph 1. b. iv:

. Land tax from individuals;

. Property tax from individuals;

. Mining tax on the exploitation of constructions materials produced in certain regions.

Period covered: 01/10/2004 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited on 3 June 2004 — Or. Engl.

The Republic of Azerbaijan declares that it will be unable to guarantee compliance with the provisions of the Convention in its territories occupied by the Republic of Armenia until these territories are liberated from that occupation (the schematic map of the occupied territories is available here).

Period covered: 01/10/2004 -

Articles concerned: -

Bahamas

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

In accordance with Article 30, paragraph 1.a, of the Convention, The Bahamas does not provide any form of assistance in relation to the taxes of other Parties in any of the categories listed in sub-paragraph b of paragraph 1 of Article 2, provided that it has not included any domestic tax in that category under Annex A of the Convention.

Period covered: 01/08/2018 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

In accordance with Article 30, paragraph 1.b, of the Convention, The Bahamas does not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes listed in paragraph 1 of Article 2.

Period covered: 01/08/2018 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

In accordance with Article 30, paragraph 1.c, of the Convention, The Bahamas does not provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made under sub-paragraph a or b above, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

Period covered: 01/08/2018 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

In accordance with Article 30, paragraph 1.d, of the Convention, The Bahamas does not provide assistance in the service of documents for all taxes listed in paragraph 1 of Article 2.

Period covered: 01/08/2018 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

In accordance with Article 30, paragraph 1.e, of the Convention, The Bahamas does not permit the service of documents through the post as provided for in paragraph 3 of Article 17.

Period covered: 01/08/2018 -

Articles concerned: 30, 17

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

In accordance with Article 30, paragraph 1.f, of the Convention, The Bahamas applies Article 28, paragraph 7, of the Convention exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

Period covered: 01/08/2018 -

Articles concerned: 30, 28

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

ANNEX C — Definition of the word «national» for the purpose of the Convention

In The Bahamas the term «national» is used when there is a reference to a person (whether natural person or legal person) in the international arena, for example, a «national» of The Bahamas or a «National» of a State. However, when referring to a person domestically (in the domestic legislation) a person is considered a citizen, not a national.

Period covered: 01/08/2018 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

ANNEX B — Competent Authorities

The Minister of Finance or his authorised representative.

Period covered: 01/08/2018 -

Articles concerned: 3

Declaration transmitted by the Ministry of Foreign Affairs of The Bahamas to the Secretariat General of the OECD on 26 April 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 01/08/2018 -

Articles concerned: 28

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 26 April 2018 — Or. Engl.

ANNEX A — Existing taxes to which the Convention shall apply

Article 2, paragraph 1.b.ii: Compulsory social security contributions payable to general government.

Article 2, paragraph 1.b.iii.B: Taxes on immovable property.

Article 2, paragraph 1.b.iii.C: General consumption taxes, such as value-added or sales taxes.

Article 2, paragraph 1.b.iii.D: Specific taxes on goods and services such as excise taxes.

Article 2, paragraph 1.b.iii.E: Taxes on the use or ownership of motor vehicles.

Period covered: 01/08/2018 -

Articles concerned: 2

Bahrain

Declaration transmitted by the Embassy of the Kingdom of Bahrain in Paris to the Secretariat General of the OECD on 11 May 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 01/09/2018 -

Articles concerned: 28

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

The Kingdom of Bahrain declares its intention, as a general rule, in accordance with paragraph 3 of Article 9 of the Convention, not to accept applications from applicant States that allows the presence of representatives of its competent authority in the appropriate part of the tax examination in the Kingdom of Bahrain.

Period covered: 01/09/2018 -

Articles concerned: 9

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

The Kingdom of Bahrain declares that, in accordance with paragraph 3 of Article 4 of the Convention, the competent authority of the Kingdom of Bahrain may, when applying Articles 5 and 7 of the Convention, inform its citizens and residents before sending information concerning them.

Period covered: 01/09/2018 -

Articles concerned: 7, 5, 4

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

Pursuant to paragraph 1.a of Article 30 of the Convention, the Kingdom of Bahrain reserves the right not to provide any form of assistance with respect to the taxes of other State Parties to the Convention in any of the categories listed in paragraph 1.b of Article 2 of the Convention, which are not included in Annex A of the Kingdom of Bahrain.

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

Pursuant to paragraph 1.b of Article 30 of the Convention, the Kingdom of Bahrain reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes listed in paragraph 1 of Article 2.

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

Pursuant to paragraph 1.d of Article 30 of the Convention, the Kingdom of Bahrain reserves the right not to provide assistance in the service of documents for all taxes listed in paragraph 1 of Article 2.

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

Pursuant to paragraph 1.f of Article 30 of the Convention, the Kingdom of Bahrain reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Kingdom of Bahrain, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Kingdom of Bahrain.

Period covered: 01/09/2018 -

Articles concerned: 30, 28

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

ANNEX B — Competent Authorities

The Minister of Finance or his authorised representative.

Period covered: 01/09/2018 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

The Kingdom of Bahrain declares that the Convention shall apply to all parts of the territory of the Kingdom of Bahrain and shall include the Kingdom's territory, subsoil, territorial waters adjacent to it, its seabed and all of which the Kingdom's sovereignty and jurisdiction is exercised in accordance with principals of international law.

Period covered: 01/09/2018 -

Articles concerned: 29

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 3 May 2018 — Or. Engl.

ANNEX A — Existing taxes to which the Convention shall apply

Article 2, paragraph 1.a.i: Income tax established by Legislative Decree No. 22 for the year 1979.

Period covered: 01/09/2018 -

Articles concerned: 2

Barbados

Declaration transmitted by a Note Verbale from the Embassy of Barbados in Brussels, dated 11 December 2017, registered at the Secretariat General of the OECD on 15 December 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 15/12/2017 -

Articles concerned: 28

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Pursuant to Article 9, paragraph 3, of the Convention, Barbados will not accept, as a general rule, requests referred to in Article 9, paragraph 1, of the Convention.

Period covered: 01/11/2016 -

Articles concerned: 9

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Pursuant to Article 4, paragraph 3, of the Convention, Barbados may inform its resident or national before transmitting information to another party, in conformity with Article 5 and Article 7 of the Convention.

Period covered: 01/11/2016 -

Articles concerned: 4

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, Barbados reserves the right not to provide any form of assistance in relation to the taxes of other Parties described in any of the categories listed in Article 2, paragraph 1.b., of the Convention.

Period covered: 01/11/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1.b, of the Convention, Barbados reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

Period covered: 01/11/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1.c, of the Convention, Barbados reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Barbados, or, if the tax claim is in relation to taxes which are listed in the reservation made under Article 30, paragraph 1. a or b of the Convention, at the date of withdrawal of such a reservation by Barbados.

Period covered: 01/11/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1.d, of the Convention, Barbados will not provide assistance in the service of documents for all taxes.

Period covered: 01/11/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1.e, of the Convention, Barbados reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.

Period covered: 01/11/2016 -

Articles concerned: 30, 17

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1.f, of the Convention, Barbados reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Barbados, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Barbados.

Period covered: 01/11/2016 -

Articles concerned: 30, 28

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Annex C — Definition of the term «national» for the purpose of the Convention

For the purposes of Article 3, paragraph 1.e, of the Convention, the term «national» in relation to Barbados means any individual possessing the nationality or citizenship of Barbados; and any legal person, partnership or association deriving its status as such from the laws in force in Barbados.

Period covered: 01/11/2016 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

Barbados ratifies the Convention with the following declaration:

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i: Income tax.

Article 2, paragraph 1.a.ii: Corporation tax.

Period covered: 01/11/2016 -

Articles concerned: 2

Declaration deposited with the Secretary General of the OECD at the time of signature of the instrument, on 28 October 2015 — Or. Engl., and confirmed in the instrument of ratification deposited with the Secretary General of the OECD, on 4 July 2016 — Or. Engl.

ANNEX B — Competent authorities

The Barbados Revenue Authority.

Period covered: 01/11/2016 -

Articles concerned: 3

Belgium

Declaration contained in a letter from the Permanent Representative, dated 7 February 1992, handed over at the time of signature on 7 February 1992 — Or. Fr. — and amended at the time of deposit of the instrument of ratification with the Secretary General of OECD, on 1 August 2000.

ANNEX A — Taxes to which the Convention would apply

I. Article 2, § 1.a.i:

Personal tax,

Corporation tax,

Tax on legal persons,

Tax on non-residents,

Withholding tax on income from movable assets (tax on capital incomes), income tax deducted at source

Special surcharge on tax on non-residents

II. Article 2, § 1.b.i:

Special surcharge on personal tax,

Withholding tax on income from immovable assets (property tax) and surcharge.

III. Article 2, § 1.b.iii:

Under category A:

Registration duties on gifts inter vivos.

Under category C:

Value added tax.

Under category D:

Excise duties,

Special excise duties,

Annual tax on insurance policies,

Annual tax on profit sharing.

IV. Article 2, § 1.b.iv:

Under category A:

Death duties and duties on transfers following death.

Period covered: 01/12/2000 -

Articles concerned: 2

Declaration contained in a letter from the Permanent Representative, dated 7 February 1992, handed over at the time of signature on 7 February 1992 — Or. Fr. — and confirmed at the time of deposit of the instrument of ratification with the Secretary General of OECD, on 1 August 2000.

ANNEX B — Competent authorities

Minister for Finance or an authorised representative.

Period covered: 01/12/2000 -

Articles concerned: 3

Declaration contained in a letter from the Permanent Representative, dated 7 February 1992, handed over at the time of signature on 7 February 1992 — Or. Fr. — and confirmed at the time of deposit of the instrument of ratification with the Secretary General of OECD, on 1 August 2000.

ANNEX C — Definition of the word «national» for the purpose of the Convention

None.

Period covered: 01/12/2000 -

Articles concerned: 3

Reservation contained in a letter from the Permanent Representative, dated 7 February 1992, handed over at the time of signature on 7 February 1992 — Or. Fr. — and confirmed at the time of deposit of the instrument of ratification with the Secretary General of OECD, on 1 August 2000.

To Article 30, § 1.a, of the Convention

Belgium reserves the right not to provide any forms of assistance in relation to the taxes of other Parties in any of the categories listed in sub-paragraph b of paragraph 1 of Article 2:

ii.: Compulsory social security contributions payable to general government or to social security institutions established under public law;

iii. B: Taxes on immovable property;

iii. E: Taxes on the use or ownership of motor-vehicles;

iii. F: Taxes on the use or ownership of movable property other than motor-vehicles;

iii. G: Any other taxes;

iv. B: Taxes on immovable property;

iv. C: General consumption taxes, such as value-added or sales taxes;

iv. D: Specific taxes on goods and services such as excise duties;

iv. E: Taxes on the use or ownership of motor-vehicles;

iv. F: Taxes on the use or ownership of movable property other than motor-vehicles;

iv. G: Any other taxes.

Period covered: 01/12/2000 -

Articles concerned: 30

Reservation contained in a letter from the Permanent Representative, dated 7 February 1992, handed over at the time of signature on 7 February 1992 — Or. Fr. — and confirmed at the time of deposit of the instrument of ratification with the Secretary General of OECD, on 1 August 2000.

To Article 30, § 1.c, of the Convention

Belgium reserves the right not to provide assistance in respect of any tax claim:

• which is in existence at the date of entry into force of the Convention in respect of Belgium;
• which was the subject of a reservation by Belgium based on Article 30, § 1.a of the Convention and was already in existence at the date of withdrawal by Belgium of such a reservation.

Period covered: 01/12/2000 -

Articles concerned: 30

Declaration transmitted by a letter from the Permanent Representation of Belgium to the OECD and UNESCO, dated 28 September 2017, registered at the Secretariat General of the OECD on 28 September 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 28/09/2017 -

Articles concerned: 28

Declaration transmitted by a letter from the Permanent Representation of Belgium to the OECD and UNESCO, dated 28 September 2017, registered at the Secretariat General of the OECD on 28 September 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 28/09/2017 -

Articles concerned: 28

Belize

Reservations contained in the instrument of acceptance deposited with the Secretary General of the OECD on 29 May 2013 — Or. Engl.

In accordance with Article 30, paragraph 1.b, of the Convention, Belize reserves the right not to provide assistance in the recovery of any tax claim or in the recovery of administrative fine, for all taxes.

In accordance with Article 30, paragraph 1.d, of the Convention, Belize reserves the right not to provide assistance in the service of documents for all taxes.

Period covered: 01/09/2013 -

Articles concerned: 30

Declaration contained in the instrument of acceptance deposited with the Secretary General of the OECD on 29 May 2013 — Or. Engl.

ANNEX B — Competent Authorities

In relation to Belize, the term «competent authority» means the Financial Secretary in the Ministry of Finance.

Period covered: 01/09/2013 -

Articles concerned: 3

Declaration contained in the instrument of acceptance deposited with the Secretary General of the OECD on 29 May 2013 — Or. Engl.

ANNEX C — Definition of the word «national» for the purpose of the Convention

In relation to Belize, the term «national» means any individual possessing the citizenship of Belize.

Period covered: 01/9/2013 -

Articles concerned: 3

Declaration contained in the instrument of acceptance deposited with the Secretary General of the OECD on 29 May 2013 — Or. Engl.

Pursuant to Article 29, paragraph 1, of the Convention, Belize declares that with respect to Belize, the Convention shall apply to the territory of Belize as defined in Schedule 1 to the Belize Constitution, including the territorial waters and any other area in the sea and in the air within which Belize, in accordance with international law, exercises sovereign rights or its jurisdiction.

Period covered: 01/09/2013 -

Articles concerned: 29

Declaration contained in the instrument of acceptance deposited with the Secretary General of the OECD on 29 May 2013 — Or. Engl.

Annex A — Taxes to which the Convention would apply:

Article 2, paragraph 1.a.i:

Income Tax (including surtax or surcharge)

Business Tax

Article 2, paragraph 1.b.iii. C:

General Sales Tax.

Period covered: 01/09/2013 -

Articles concerned: 2

Benin

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 24 January 2023 — Or. Fr.

[Note by the Secretariat: The text of this reservation will soon be available on this web site.]

Period covered: 01/05/2023

Articles concerned: 2 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 24 January 2023 — Or. Fr.

[Note by the Secretariat: The text of this reservation will soon be available on this web site.]

Period covered: 01/05/2023

Articles concerned: 28 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 24 January 2023 — Or. Fr.

[Note by the Secretariat: The text of this declaration will soon be available on this web site.]

Period covered: 01/05/2023

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 24 January 2023 — Or. Fr.

[Note by the Secretariat: The text of this declaration will soon be available on this web site.]

Period covered: 01/05/2023

Articles concerned: 3

Bosnia and Herzegovina

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 21 September 2020 — Or. Engl.

In accordance with Article 30, paragraph 1, subparagraph a of the Convention, Bosnia and Herzegovina reserves the right not to provide any form of assistance with respect to the taxes of other parties in any of the following categories mentioned in subparagraph b, paragraph 1 of Article 2:

i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party,

ii. compulsory social security contributions payable to general government or to social security institutions established under public law,

iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

• A: estate, inheritance or gift taxes,
• B: taxes on immovable property,
• D: specific taxes on goods and services such as excise taxes,
• E: taxes on the use or ownership of motor vehicles,
• F: taxes on the use or ownership of movable property, other than motor vehicles,
• G: any other taxes,

iv. taxes in categories referred to in subparagraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

Period covered: 01/01/2021 -

Articles concerned: 30, 2

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 21 September 2020 — Or. Engl.

In accordance with Article 30, paragraph 1, subparagraph b of the Convention, Bosnia and Herzegovina reserves the right not to provide assistance in the recovery of any tax claim or administrative fines, for taxes stated in the reservation made toward Article 30, paragraph 1, subparagraph a, of the Convention. In accordance with Article 30, paragraph 1, subparagraph c of the Convention, Bosnia and Herzegovina reserves the right not to provide assistance in relation to any tax claim existing at the date of entry into force of the Convention against Bosnia and Herzegovina, or if a tax claim relates to the taxes stated in the reservation made toward Article 30, paragraph 1, subparagraph a or b of the Convention, on the date of withdrawal of such reservation by Bosnia and Herzegovina. In accordance with Article 30, paragraph 1, subparagraph d of the Convention, Bosnia and Herzegovina reserves the right not to provide assistance with the submission of documents for the taxes specified in the reservation made toward Article 30, paragraph 1, subparagraph a of the Convention.

Period covered: 01/01/2021 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 21 September 2020 — Or. Engl.

In accordance with Article 30, paragraph 1, subparagraph f of the Convention, Bosnia and Herzegovina reserves the right to apply Article 28, paragraph 7, exclusively for administrative assistance relating to tax periods beginning on or after 1 January of the third year preceding that in which the Convention, as amended by the 2010 Protocol, entered into force with respect to Bosnia and Herzegovina, or in the absence of a tax period, for administrative assistance relating to tax liabilities incurred on or after I January of the third year preceding that in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Bosnia and Herzegovina.

Period covered: 01/01/2021 -

Articles concerned: 30, 28

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 21 September 2020 — Or. Engl

ANNEX B — Competent authorities

For taxes referred to in Article 2, paragraph 1, subparagraph a.i., the competent authorities shall be as follows: the Federal Ministry of Finance for the territory of the Federation BiH; the Ministry of Finance of Republika Srpska for the territory of Republika Srpska, and the Br ko District Finance Directorate for the territory of the Br ko District;

For taxes referred to in Article 2, paragraph 1, subparagraph b.iii.C, the competent authority shall be the Indirect Taxation Authority.

Period covered: 01/01/2021 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 21 September 2020 — Or. Engl

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i:

• Personal income tax;
• Corporate income tax.

Article 2, paragraph 1.b.iii.C:

• Value Added Tax.

Period covered: 01/01/2021 -

Articles concerned: 2

Botswana

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 15 June 2021 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Botswana will not provide any form of assistance in relation to the taxes of other Parties included in the following categories of Article 2, paragraph 1:

. Article 2, paragraph 1.b.i;

. Article 2, paragraph 1.b.ii;

. Article 2, paragraph 1.b.iii.E;

. Article 2, paragraph 1.b.iii.F;

. Article 2, paragraph 1.b.iii.G, and

. Article 2, paragraph 1.b.iv.

Period covered: 01/10/2021 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 15 June 2021 — Or. Engl.

Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Botswana will not provide assistance with regard to the service of documents as described in Article 17 of the Convention, for all taxes. This reservation does not apply to the service of documents as described in Article 17, paragraph 3, of the Convention.

Period covered: 01/10/2021 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 15 June 2021 — Or. Engl.

The Republic of Botswana ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters, with the following notification:

ANNEX B — Competent Authorities

The Minister responsible for finance represented by the Commissioner General of the Botswana Unified Revenue Service (BURS) or an authorised representative of the Commissioner General.

Period covered: 01/10/2021 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 15 June 2021 — Or. Engl.

The Republic of Botswana ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters, with the following notification:

ANNEX C — Definition of a «national» for the purpose of the Convention

Any individual possessing the nationality or citizenship of Botswana and any legal person, association, or other entity deriving its status as such from the laws in force in Botswana.

Period covered: 01/10/2021 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 15 June 2021 — Or. Engl.

The Republic of Botswana ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters, with the following notification:

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i:

• Income tax;
• Withholding tax on royalties;
• Withholding tax on dividend tax;
• Withholding tax on interest;
• Withholding tax on technical fees;
• Withholding tax on tax on foreign entertainers and sportspersons.

Article 2, paragraph 1.a.ii: Capital gains tax.

Article 2, paragraph 1.b.iii.A: Capital transfer tax.

Article 2, paragraph 1.b.iii.B: Transfer duty.

Article 2, paragraph 1.b.iii.C: Value added tax.

Article 2, paragraph 1.b.iii.D: Excise duty.

Period covered: 01/10/2021 -

Articles concerned: 2

Brazil

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 1 June 2016 — Or. Engl.

ANNEX A — Taxes to which the Convention applies

Article 2, paragraph 1:

a) paragraph 1.a.i: Income Tax and Social Contribution on Net Profits;

b) paragraph 1.b.ii: Contribution for the Program for Social Integration and Social Contribution for the Financing of Social Security;

c) paragraph 1.b.iii.D: Tax on Industrialized Products;

d) paragraph 1.b.iii.G: any other taxes administered by the Secretariat of the Federal Revenue of Brazil.

Period covered: 01/10/2016 -

Articles concerned: 2

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 1 June 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1(b), of the Convention, the Government of Brazil will not provide assistance in the recovery of any tax claim, or in the recovery of administrative fines, for all taxes.

Period covered: 01/10/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 1 June 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1(d), of the Convention, the Government of Brazil will not provide assistance in the service of documents for all taxes.

Period covered: 01/10/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 1 June 2016 — Or. Engl.

Pursuant to Article 30, paragraph 1(e), of the Convention, the Government of Brazil will not permit the service of documents through the post, as provided for in paragraph 3 of Article 17 of the Convention.

Period covered: 01/10/2016 -

Articles concerned: 17, 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 1 June 2016 — Or. Engl.

ANNEX B — Competent Authorities

The Competent Authority for the Federative Republic of Brazil is the Secretary of the Federal Revenue of Brazil.

Period covered: 01/10/2016 -

Articles concerned: 3

Declaration transmitted by the Secretary of the Federal Revenue of Brazil to the Secretariat General of the OECD on 23 March 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 23/03/2017 -

Articles concerned: 28

Declaration transmitted by the Delegate of Brazil to International Economic Organisations in Paris to the Secretariat General of the OECD on 29 March 2018 — Or. Engl

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 29/03/2018 -

Articles concerned: 28

Brunei Darussalam

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

ANNEX A — Taxes to which the Convention would Apply

Article 2, paragraph 1.a.i:

• Income tax imposed under Income Tax Act (Chapter 35), and
• Petroleum profits tax imposed under Income Tax (Petroleum) Act (Chapter 119).

Period covered: 01/07/2019 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

ANNEX B — Competent authorities

For the purposes of Article 3, paragraph 1.d, of the Convention, the term «competent authority» in relation to Brunei Darussalam means the Minister of Finance and Economy or his authorised representative.

Period covered: 01/07/2019 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

ANNEX C — Definition of the word «national» for the purpose of the Convention

For the purposes of Article 3, paragraph 1.e, of the Convention, the term «national» in relation to Brunei Darussalam means any individual possessing the nationality of Brunei Darussalam, and any legal person, partnership or association deriving its status as such from the laws in force in the Brunei Darussalam.

Period covered: 01/07/2019 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

In accordance with Article 4, paragraph 3, of the Convention, Brunei Darussalam declares that its authorities may inform its resident or national before transmitting information concerning him, in conformity with Articles 5 and 7 of the Convention.

Period covered: 01/07/2019 -

Articles concerned: 4, 5, 7

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

In accordance with Article 9, paragraph 3, of the Convention, Brunei Darussalam declares that it will not accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the Convention.

Period covered: 01/07/2019 -

Articles concerned: 9

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, Brunei Darussalam reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the categories listed in Article 2, paragraph 1.b.

Period covered: 01/07/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

Pursuant to Article 30, paragraph 1.b, of the Convention, Brunei Darussalam reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

Period covered: 01/07/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

Pursuant to Article 30, paragraph 1.c, of the Convention, Brunei Darussalam reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of Brunei Darussalam or, where a reservation has previously been made under sub-paragraph a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

Period covered: 01/07/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

Pursuant to Article 30, paragraph 1.d, of the Convention, Brunei Darussalam reserves the right not to provide assistance in the service of documents for all taxes.

Period covered: 01/07/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

Pursuant to Article 30, paragraph 1.e, of the Convention, Brunei Darussalam reserves the right not to permit the service of documents through the post as provided for in Article 17, paragraph 3.

Period covered: 01/07/2019 -

Articles concerned: 17, 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 28 March 2019 — Or. Engl.

Pursuant to Article 30, paragraph 1.f, of the Convention, Brunei Darussalam reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Brunei Darussalam, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of Brunei Darussalam.

Period covered: 01/07/2019 -

Articles concerned: 28, 30

Declaration transmitted by the Embassy of Brunei Darussalam to France and registered at the Secretariat General of the OECD on 2 January 2020 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 02/01/2020 -

Articles concerned: 28

Bulgaria

Declaration contained in a Note Verbale from the Minister of Finance of the Republic of Bulgaria, dated 21 October 2015, registered at the Secretariat General of the OECD on 17 December 2015 — Or. Engl.

ANNEX B — Competent Authorities

The Minister of Finance of the Republic of Bulgaria or his, her authorised representative.

Articles concerned: 3

Declaration contained in a Note Verbale from the Permanent Representation of Bulgaria and in the instrument of ratification, deposited simultaneously on 14 March 2016 — Or. Engl.

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i:

. Personal income tax

. Corporate income tax

Article 2, paragraph 1.a.ii:

. --

Article 2, paragraph 1.a.iii:

. --

Article 2, paragraph 1.b.i:

. --

Article 2, paragraph 1.b.ii:

. Compulsory social security contributions payable to general government or to social security institutions established under public law.

Article 2, paragraph 1.b.iii.A:

. --

Article 2, paragraph 1.b.iii.B:

. --

Article 2, paragraph 1.b.iii.C:

. Value added tax

Article 2, paragraph 1.b.iii.D:

. --

Article 2, paragraph 1.b.iii.E:

. --

Article 2, paragraph 1.b.iii.F:

. --

Article 2, paragraph 1.b.iii.G:

. --

Period covered: 01/07/2016 -

Articles concerned: 2

Declaration contained in a Note Verbale from the Permanent Representation of Bulgaria and in the instrument of ratification, deposited simultaneously on 14 March 2016 — Or. Engl.

ANNEX B — Competent authorities

The Minister of Finance, the Executive Director of the National Revenue Agency or their authorised representative will be the competent authorities in Bulgaria under Annex B of the Convention.

Period covered: 01/07/2016 -

Articles concerned: 3

Declaration transmitted by the Permanent Representation of Bulgaria at the time of deposit of the instrument of ratification on 14 March 2016 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information pursuant to Article 28, paragraph 6 of the Convention as amended by the Protocol.

Period covered: 01/07/2016 -

Articles concerned: 28

Declaration transmitted by a letter from the Ambassador of Bulgaria in France, dated 24 November 2017, registered at the Secretariat General of the OECD on 30 November 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 30/11/2017 -

Articles concerned: 28

Burkina Faso

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 13 December 2022 — Or. Fr.

In accordance with Article 30, paragraph 1.a, of the Convention, Burkina Faso will not provide any form of assistance in relation to the taxes of other Parties in any of the categories mentioned in Article 2, paragraph 1.b, of the Convention.

Period covered: 01/04/2023

Articles concerned: 2 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 13 December 2022 — Or. Fr.

In accordance with Article 30, paragraph 1.e, of the Convention, Burkina Faso will not permit the service of documents through the post as provided for in Article 17, paragraph 3, of the Convention.

Period covered: 01/04/2023

Articles concerned: 17 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 13 December 2022 — Or. Fr.

Burkina Faso ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters, with the following notification:

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i: Personal income tax.

Article 2, paragraph 1.a.ii: Capital gains tax.

Period covered: 01/04/2023

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 13 December 2022 — Or. Fr.

Burkina Faso ratifies the Convention on Mutual Administrative Assistance in Tax Matters as amended by the Protocol amending the Convention on Mutual Administrative Assistance in Tax Matters, with the following notification:

ANNEX B — Competent Authorities

The Minister responsible for Finance and the Director General for Taxes.

Period covered: 01/04/2023

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 13 December 2022 — Or. Fr.

In accordance with Article 9, paragraph 3, of the Convention, Burkina Faso declares that the competent authority of Burkina Faso reserves the right to not accept, as a general rule, requests of the competent authority of the applicant State to be present at the appropriate part of a tax examination in the requested State, namely Burkina Faso.

Period covered: 01/04/2023

Articles concerned: 9

Cabo Verde

Reservation contained in a Note Verbale from the Ministry of Foreign Affairs and Communities of Cabo Verde, dated 27 December 2019, accompanying the instrument of ratification deposited with the Secretary General of the OECD on 6 January 2020 — Or. Engl.

In accordance with Article 30, paragraph 1.a of the Convention, the Republic of Cabo Verde will not provide any form of assistance in relation to the taxes of other Parties in any of the categories listed in sub-paragraph b. of paragraph 1 of Article 2, except for those mentioned in letters C) and D of paragraph 1.b iii) of Article 2, as included in Annex A.

Period covered: 01/05/2020 -

Articles concerned: 30

Reservation contained in a Note Verbale from the Ministry of Foreign Affairs and Communities of Cabo Verde, dated 27 December 2019, accompanying the instrument of ratification deposited with the Secretary General of the OECD on 6 January 2020 — Or. Engl.

In accordance with Article 30, paragraph 1.b of the Convention, the Republic of Cabo Verde will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes listed in paragraph 1.b of Article 2, except for those mentioned in letters C) and D of paragraph 1.b iii) of Article 2, as included in Annex A.

Period covered: 01/05/2020 -

Articles concerned: 30

Reservation contained in a Note Verbale from the Ministry of Foreign Affairs and Communities of Cabo Verde, dated 27 December 2019, accompanying the instrument of ratification deposited with the Secretary General of the OECD on 6 January 2020 — Or. Engl.

In accordance with Article 30, paragraph 1.c of the Convention, the Republic of Cabo Verde will not provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of the Republic of Cabo Verde.

Period covered: 01/05/2020 -

Articles concerned: 30

Reservation contained in a Note Verbale from the Ministry of Foreign Affairs and Communities of Cabo Verde, dated 27 December 2019, accompanying the instrument of ratification deposited with the Secretary General of the OECD on 6 January 2020 — Or. Engl.

In accordance with Article 30, paragraph 1.d of the Convention, the Republic of Cabo Verde will not provide assistance in the service of documents for all taxes listed in paragraph 1.b of Article 2, except for those mentioned in letters C) and D of paragraph 1.b iii) of Article 2, as included in Annex A.

Period covered: 01/05/2020 -

Articles concerned: 30

Declaration contained in a Note Verbale from the Ministry of Foreign Affairs and Communities of Cabo Verde, dated 27 December 2019, accompanying the instrument of ratification deposited with the Secretary General of the OECD on 6 January 2020 — Or. Engl.

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i:

• Personal Income Tax («Imposto sobre o Rendimento das Pessoas Singulares»)
• Corporate Income Tax («Imposto sobre o Rendimento das Pessoas Colectivas»)

Article 2, paragraph 1.a.ii:

• Single Property Tax («Imposto unico sobre o patrimonio, no que diz respeito aos ganhos derivados da alienaçao de bens imobiliarios»)

Article 2, paragraph 1.b.iii.C:

• Value Added Tax («Imposto sobre o Valor Acrescentado»)

Article 2, paragraph 1.b.iii.D:

• Special Consumption Tax («Imposto sobre Consumos Especiais»)

Period covered: 01/05/2020 -

Articles concerned: 2

Declaration contained in a Note Verbale from the Ministry of Foreign Affairs and Communities of Cabo Verde, dated 27 December 2019, accompanying the instrument of ratification deposited with the Secretary General of the OECD on 6 January 2020 — Or. Engl.

ANNEX B — Competent authorities

The Vice-Prime Minister and Minister of Finance, the National Director of State Revenues or their authorised representatives.

Period covered: 01/05/2020 -

Articles concerned: 3

Cameroon

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 30 June 2015 — Or. Fr.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Cameroon will not provide any form of assistance in relation to the taxes of other Parties in the following categories listed in Article 2, paragraph 1.b, of the Convention:

i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

ii. compulsory social security contributions payable to general government or to social security institutions established under public law;

iii. taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

A. estate, inheritance or gift taxes,

B. taxes on immovable property,

E. taxes on the use or ownership of motor vehicles,

F. taxes on the use or ownership of movable property other than motor vehicles,

iv. taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Cameroon will not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

Period covered: 01/10/2015 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 30 June 2015 — Or. Fr.

For the purposes of this Convention, the territory of Cameroon means the territory of the Republic of Cameroon including the territorial sea and beyond it any areas outside the territorial waters of Cameroon on which in accordance with international law, Cameroon has sovereign rights for the purpose of exploitation of natural resources of the seabed and its subsoil and underlying waters.

Period covered: 01/10/2015 -

Articles concerned: -

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 30 June 2015 — Or. Fr.

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i

Personal income Tax,

Corporate income tax;

Special tax on income;

Article 2, paragraph 1.a.ii

Taxes on capital gains which are imposed separately from the tax on income or profits

Article 2, paragraph 1.b.iii.C

Value-added tax;

Article 2, paragraph 1.b.iii.D

Excise tax

Period covered: 01/10/2015 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 30 June 2015 — Or. Fr.

ANNEX B — Competent Authorities

The Minister of Finance or its representative.

Period covered: 01/10/2015 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 30 June 2015 — Or. Fr.

ANNEX C — Definition of the word «national» for the purpose of the Convention

All individuals of Cameroonian nationality and all legal persons, partnership or capital companies, associations and other entities planned and constituted under the laws in force in Cameroon.

Period covered: 01/10/2015 -

Articles concerned: 3

Canada

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 21 November 2013 — Or. Engl. / Fr.

Canada will not provide any form of assistance in relation to the taxes of other Parties described in any of sub paragraphs 1(b)(i), (ii), (iii) A, B, E, F and G and (iv) of Article 2 of the Convention (as permitted by sub paragraph 1(a) of Article 30 of the Convention).

Period covered: 01/03/2014 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 21 November 2013 — Or. Engl. / Fr.

Annex A — Taxes to which the Convention would apply:

Article 2, paragraph 1(a): the taxes on income or profits, including capital gains that are added to income at a rate determined under the following act, and taxes on net wealth that are imposed on behalf of Canada under the Income Tax Act (Canada).

Article 2, paragraph 1(b)(iii) C: the Value Added Tax imposed on behalf of Canada under Part IX of the Excise Tax Act (Canada).

Article 2, paragraph 1(b)(iii) D: the taxes imposed on behalf of Canada under Parts I and III of the Excise Tax Act (Canada) and the Excise Act, 2001 (Canada).

Period covered: 01/03/2014 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 21 November 2013 — Or. Engl. / Fr.

The Minister of National Revenue or the Minister's authorised representative.

Period covered: 01/03/2014 -

Articles concerned: 3

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 21 November 2013 — Or. Engl. / Fr.

Canada will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for any tax, pursuant to Articles 11 through 16 of the Convention (as permitted by sub-paragraph 1(b) of Article 30 of the Convention).

Period covered: 01/03/2014 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 21 November 2013 — Or. Engl. / Fr.

Canada will not provide assistance in the service of document for any tax, pursuant to Article 17 of the Convention (as permitted by sub-paragraph 1(d) of Article 30 of the Convention); this reservation does not apply to the service of documents by mail, pursuant to paragraph 3 of Article 17 of the Convention.

Period covered: 01/03/2014 -

Articles concerned: 30

Chile

Declaration contained in a Note Verbale from the Permanent Delegation of Chile to the OECD dated 29 May 2015, registered at the Secretariat of the OECD on 2 June 2015 — Or. Engl., and confirmed in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

ANNEX B — Competent Authorities

The Minister of Finance, the Commissioner of the Chilean Internal Revenue Service, and their authorised representatives.

Period covered: 01/11/2016 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i: Tax included in the income tax.

Article 2, paragraph 1.a.ii: Sales and Services Tax Act.

Article 2, paragraph 1.a.iii: Estate, inheritance or gift taxes.

Period covered: 01/11/2016 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

ANNEX C — Definition of the term «national» for the purpose of the Convention

The Republic of Chile, according to Article 3, paragraph 1.e, of the Convention, declares that the term «national» means any individual possessing the Chilean nationality; and any legal person or association organised under the laws in force in the Republic of Chile.

Period covered: 01/11/2016 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

According to Article 4, paragraph 3, of the Convention, the Republic of Chile declares that its authorities may inform its resident before transmitting information concerning them, in conformity with Article 5 and Article 7 of the Convention.

Period covered: 01/11/2016 -

Articles concerned: 4

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

According to Article 9, paragraph 3, of the Convention, the Republic of Chile will not accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the Convention.

Period covered: 01/11/2016 -

Articles concerned: 9

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

According to Article 30, paragraph 1.a, of the Convention, the Republic of Chile reserves the right not to provide any form assistance in relation to the taxes of other Parties, save for the ones included by Chile in Annex A to the Convention.

Period covered: 01/11/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

According to Article 30, paragraph 1.b, of the Convention, the Republic of Chile reserves the right not to provide any assistance in the recovery of any tax claim or in the recovery of an administrative fine, for all taxes.

Period covered: 01/11/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

According to Article 30, paragraph 1.d, of the Convention, the Republic of Chile reserves the right not to provide assistance in the service of documents.

Period covered: 01/11/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

According to Article 30, paragraph 1.e, of the Convention, the Republic of Chile reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17 of the Convention.

Period covered: 01/11/2016 -

Articles concerned: 17, 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 7 July 2016 — Or. Engl.

According to Article 30, paragraph 1.f, of the Convention, the Republic of Chile reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention entered into force in respect of Chile, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention entered into force in respect of Chile.

Period covered: 01/11/2016 -

Articles concerned: 28, 30

China

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 16 October 2015 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the People's Republic of China shall not provide any form of assistance in relation to the taxes of other Parties described in sub-paragraphs b.i, b.ii, b.iii.A, b.iii.F, and b.iv of paragraph 1 of Article 2.

Period covered: 01/02/2016 -

Articles concerned: 2, 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 16 October 2015 — Or. Engl.

Pursuant to Article 30, paragraph 1.b, of the Convention, the People's Republic of China shall not provide assistance in the recovery of tax claims, or in conservancy measures, for all taxes.

Period covered: 01/02/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 16 October 2015 — Or. Engl.

Pursuant to Article 30, paragraph 1.d, of the Convention, the People's Republic of China shall not provide assistance in the service of documents for all taxes.

Period covered: 01/02/2016 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD, on 16 October 2015 — Or. Engl.

Pursuant to Article 30, paragraph 1.e, of the Convention, the People's Republic of China shall not permit the service of documents through the post.

Period covered: 01/02/2016 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 16 October 2015 — Or. Engl.

Pursuant to. Article 2, paragraph 1, of the Convention, for the People's Republic of China, the Convention shall apply to the following taxes imposed under the laws of the People's Republic of China administered by the tax authority:

Annex A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i

. Enterprise Income Tax.

. Individual Income Tax.

Article 2, paragraph 1.b.iii.B

. Urban and Township Land Use Tax.

. House Property Tax.

. Land Appreciation Tax.

Article 2, paragraph 1.b.iii.C

. Value Added Tax.

. Business Tax.

Article 2, paragraph 1.b.iii.D

. Excise Tax.

. Tobacco Tax.

Article 2, paragraph 1.b.iii.E

. Vehicle Purchase Tax.

. Vehicle and Vessel Tax.

Article 2, paragraph 1.b.iii.G

. Resource Tax

. City Maintenance and Construction Tax.

. Tax on the Use of Arable Land.

. Stamp Duty.

. Deed Tax.

Period covered: 01/02/2016 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 16 October 2015 — Or. Engl.

Pursuant to Article 4, paragraph 3, of the Convention, the People's Republic of China may inform its resident or national before transmitting information concerning him to another Party, in conformity with Articles 5 and 7 of the Convention.

Period covered: 01/02/2016 -

Articles concerned: 4

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD, on 16 October 2015 — Or. Engl.

ANNEX B — Competent Authorities

Pursuant to Article 3, paragraph 1.d, of the Convention, for the People's Republic of China, the term «competent authority» means the State Administration of Taxation or its authorised representative.

Period covered: 01/02/2016 -

Articles concerned: 3

Declaration of territorial application contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

In accordance with the Basic Law of the Hong Kong Special Administrative Region of the People's Republic of China, the Government of the PRC decides that the Convention applies to the Hong Kong Special Administrative Region (Hong Kong SAR) of the PRC.

Period covered: 01/09/2018 -

Articles concerned: 29

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

The Government of the People's Republic of China declares that the reservation pursuant to paragraph 1.a of Article 30 and the three declarations pursuant to paragraph 1 of Article 2, paragraph 1.d of Article 3 and paragraph 3 of Article 4 of the Convention made by the PRC [on 16 October 2015] shall not apply to Hong Kong SAR.

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Hong Kong SAR shall not provide any form of assistance in relation to taxes of the other Parties described in paragraph 1.b of Article 2 of the Convention.

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

The Government of the People's Republic of China declares that the reservation pursuant to paragraph 1.b of Article 30 of the Convention made by the PRC shall apply to the Hong Kong SAR: «Pursuant to Article 30, paragraph 1.b, of the Convention, the People's Republic of China shall not provide assistance in the recovery of tax claims, or in conservancy measures, for all taxes.».

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

Pursuant to Article 30, paragraph 1.c, of the Convention, the Hong Kong SAR shall not provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of the Hong Kong SAR or, where a reservation has previously been made under paragraph 1.a or 1.b of Article 30 of the Convention, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

The Government of the People's Republic of China declares that the reservation pursuant to paragraph 1.d of Article 30 of the Convention made by the PRC shall apply to the Hong Kong SAR: «Pursuant to Article 30, paragraph 1.d, of the Convention, the People's Republic of China shall not provide assistance in the service of documents for all taxes.».

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

The Government of the People's Republic of China declares that the reservation pursuant to paragraph 1.e of Article 30 of the Convention made by the PRC shall apply to the Hong Kong SAR: «Pursuant to Article 30, paragraph 1.e, of the Convention, the People's Republic of China shall not permit the service of documents through the post.».

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

Pursuant to Article 30, paragraph 1.f, of the Convention, the Hong Kong SAR apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention entered into force in respect of the Hong Kong SAR, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention entered into force in respect of the Hong Kong SAR.

Period covered: 01/09/2018 -

Articles concerned: 28, 30

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

Pursuant to Article 4, paragraph 3, of the Convention, the Hong Kong SAR may inform its resident or national before transmitting information concerning that resident or national to another Party, in conformity with Article 5 of the Convention.

Period covered: 01/09/2018 -

Articles concerned: 4

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

Pursuant to Article 9, paragraph 3, of the Convention, the Hong Kong SAR will not accept, as a general rule, such requests as are referred to in paragraph 1 of Article 9 of the Convention.

Period covered: 01/09/2018 -

Articles concerned: 9

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

ANNEX A — Taxes to which the Convention applies

For the Hong Kong SAR, the Convention shall apply to the following taxes imposed under the laws of the Hong Kong SAR administered by its tax authority:

Article 2, paragraph 1.a.i:

• Profits tax;
• Salaries tax;
• Property Tax.

Period covered: 01/09/2018 -

Articles concerned: 2

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

ANNEX B — Competent authorities

The competent authority for the Hong Kong SAR is the Commissioner of Inland Revenue of the Government of the Hong Kong SAR or the authorised representative of the Commissioner.

Period covered: 01/09/2018 -

Articles concerned: 3

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 28 May 2018, registered at the Secretariat General of the OECD on 29 May 2018 — Or. Engl.

ANNEX C — Definition of the term «national» for the purpose of the Convention

For the application of the Convention to the Hong Kong SAR, paragraph 1.e of Article 3 of the Convention refers to any person having the right to abode, or is incorporated or otherwise constituted in the Hong Kong SAR.

Period covered: 01/09/2018 -

Articles concerned: 3

Declaration of territorial application contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

In accordance with the Basic Law of the Macao Special Administrative Region of the People's Republic of China, the Government of the PRC decides that the Convention applies to the Macao Special Administrative Region of the PRC.

Period covered: 01/09/2018 -

Articles concerned: 29

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

The Government of the People's Republic of China declares that the reservation pursuant to paragraph 1.a of Article 30 and the three declarations pursuant to paragraph 1 of Article 2, paragraph 1.d of Article 3 and paragraph 3 of Article 4 of the Convention made by the PRC [on 16 October 2015] shall not apply to the Macao Special Administrative Region.

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Macao Special Administrative Region shall not provide any form of assistance in relation to taxes of the other Parties described in sub-paragraphs b.i, b.ii, b.iii.A, b.iii.C, b.iii.F and b.iv of paragraph 1 of Article 2 of the Convention.

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

The Government of the People's Republic of China declares that the reservation pursuant to paragraph 1.b of Article 30 of the Convention made by the PRC shall apply to the Macao Special Administrative Region: «Pursuant to Article 30, paragraph 1.b, of the Convention, the People's Republic of China shall not provide assistance in the recovery of tax claims, or in conservancy measures, for all taxes.».

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

The Government of the People's Republic of China declares that the reservation pursuant to paragraph 1.d of Article 30 of the Convention made by the PRC shall apply to the Macao Special Administrative Region: «Pursuant to Article 30, paragraph 1.d, of the Convention, the People's Republic of China shall not provide assistance in the service of documents for all taxes.».

Period covered: 01/09/2018 -

Articles concerned: 30

Reservation contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

The Government of the People's Republic of China declares that the reservation pursuant to paragraph 1.e of Article 30 of the Convention made by the PRC shall apply to the Macao Special Administrative Region: «Pursuant to Article 30, paragraph 1.e, of the Convention, the People's Republic of China shall not permit the service of documents through the post.».

Period covered: 01/09/2018 -

Articles concerned: 30

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

Pursuant to Article 4, paragraph 3, of the Convention, the Macao Special Administrative Region may inform its resident before transmitting information concerning him to another Party, in conformity with Articles 5 and 7 of the Convention.

Period covered: 01/09/2018 -

Articles concerned: 4

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

Pursuant to Article 9, paragraph 3, of the Convention, the Macao Special Administrative Region will not accept, as a general rule, such requests as are referred to in paragraph 14 of Article 9 of the Convention.

Period covered: 01/09/2018 -

Articles concerned: 9

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

ANNEX A — Taxes to which the Convention applies

For the Macao Special Administrative Region, the Convention shall apply to the following taxes imposed under the laws of the Macao Special Administrative Region administered by its tax authority:

Article 2, paragraph 1.a.i:

• Profits tax (Impost Complementar de Rendimentos);
• Salaries tax (Imposto Profissional);
• Urban Property Tax ( Contribuição Predial Urbana).

Article 2, Paragraph 1.b.iii.B: Stamp Duty (Imposto do Selo).

Article 2, Paragraph 1.b.iii.D: Tourism Tax (Imposto de turismo).

Article 2, Paragraph 1.b.iii.E: Motor Vehicle Tax (Imposto sobre Veículos Motorizados).

Article 2, Paragraph 1.b.iii.G: Business Tax ( Contribuição Industrial).

Period covered: 01/09/2018 -

Articles concerned: 2

Declaration contained in a letter from the Ambassador of the People's Republic of China in France, dated 29 March 2018, registered at the Secretariat General of the OECD on 18 May 2018 — Or. Engl.

ANNEX B — Competent authorities

The competent authority for the Macao Special Administrative Region is the Chief Executive of the Macao Special Administrative Region or his authorized representative.

Period covered: 01/09/2018 -

Articles concerned: 3

Declaration transmitted by the Embassy of the People's Republic of China in France to the Secretariat General of the OECD on 25 June 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 25/06/2018 -

Articles concerned: 28

Declaration transmitted by the Embassy of the People's Republic of China in France to the Secretariat General of the OECD on 25 June 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information

Period covered: 25/06/2018 -

Articles concerned: 28

Colombia

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 19 March 2014 — Or. Engl.

ANNEX A — Existing taxes to which the Convention shall apply:

The existing taxes to which the Convention shall apply within the Colombian legal system are:

Article 2, paragraph 1.a.i:

• income tax and its complementary taxes;
• Pro equity income tax — CREE;

Article 2, paragraph 1.a.ii:

• income tax and its complementary taxes;

Article 2, paragraph 1.a.iii:

• tax on capital;

Article 2, paragraph 1.b.i:

Not applicable;

Article 2, paragraph 1.b.ii:

Not applicable;

Article 2, paragraph 1.b.iii.A:

• income tax and complementary taxes;

Article 2, paragraph 1.b.iii.B:

Not applicable;

Article 2, paragraph 1.b.iii.C:

• value added tax — VAT;

Article 2, paragraph 1.b.iii.D:

• national consumption tax;

Article 2, paragraph 1.b.iii.E:

Not applicable;

Article 2, paragraph 1.b.iii.F:

Not applicable;

Article 2, paragraph 1.b.iii.G:

Not applicable.

Period covered: 01/07/2014 -

Articles concerned: 2

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 19 March 2014 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Colombia reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b, of the Convention:

i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political divisions or local authorities of a Party;

ii. compulsory social security contributions payable to general government or to social security institutions established under public law;

iii. B. taxes on immovable property;

iii. E. taxes on the use or ownership of motor vehicles;

iii. F. taxes on the use or ownership of movable property other than motor vehicles;

iii. G. any other taxes;

iv. taxes in categories referred to in sub-paragraph iii which are imposed on behalf of political subdivisions or local authorities of a Party.

Period covered: 01/07/2014 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 19 March 2014 — Or. Engl.

Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Colombia reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all the taxes.

Period covered: 01/07/2014 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 19 March 2014 — Or. Engl.

Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Colombia reserves the right not to provide assistance in the service of documents for all taxes.

Period covered: 01/07/2014 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 19 March 2014 — Or. Engl.

ANNEX B — Competent Authorities

The competent authority for the Republic of Colombia is the Director General of the National Tax and Customs Administration (Director General de la Dirección de Impuestos y Aduanas Nationales — DIAN) or his autorised representative.

Period covered: 01/07/2014 -

Articles concerned: 3

Declarations transmitted by a Note Verbale from the Ministry of Foreign Affairs of Colombia, dated 13 December 2017, registered at the Secretariat General of the OECD on 20 December 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 20/12/2017 -

Articles concerned: 28

Cook Islands

Declaration contained in a Note Verbale from the Ministry of Foreign Affairs and Immigration of the Cook Islands, dated 22 March 2017, supplementing the instrument of ratification deposited with the Secretary General of the OECD on 29 May 2017 — Or. Engl.

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i:

• Taxes on income or profits, including withholding taxes

Article 2, paragraph 1.b.iii.C:

• Value Added Tax

Article 2, paragraph 1.b.iii.D:

• Excise Taxes on alcohol and sugar

Period covered: 01/09/2017 -

Articles concerned: 2

Declaration contained in a Note Verbale from the Ministry of Foreign Affairs and Immigration of the Cook Islands, dated 22 March 2017, supplementing the instrument of ratification deposited with the Secretary General of the OECD on 29 May 2017 — Or. Engl.

ANNEX B — Competent authorities

The Treasurer of Revenue Management or his authorised representative.

Period covered: 01/09/2017 -

Articles concerned: 3

Declaration contained in a Note Verbale from the Ministry of Foreign Affairs and Immigration of the Cook Islands, dated 22 March 2017, supplementing the instrument of ratification deposited with the Secretary General of the OECD on 29 May 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 29/05/2017 -

Articles concerned: 28

Costa Rica

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 5 April 2013 — Or. Spa./Engl.

ANNEX A — Existing taxes to which the Convention shall apply:

Article 2, paragraph 1.a.i:

Income Tax (Impuesto sobre la renta).

Article 2, paragraph 1.b.ii:

Contributions made to the Costa Rican Social Security (Contribuciones a la caja Costarricense del Seguro Social).

Article 2, paragraph 1.b.iii. B:

Real estate tax (Impuesto a la propriedad de bienes inmuebles).

Article 2, paragraph 1.b.iii. C:

Value Added Tax (Impuesto general sobre las ventas).

Article 2, paragraph 1.b.iii. E:

Vehicles, ships and aircrafts tax (Impuesto a la propriedad de vehículos , embarcaciones y aeronaves).

Period covered: 01/08/2013 -

Articles concerned: 2

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 5 April 2013 — Or. Spa./Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, Costa Rica reserves the right not to provide any form of assistance in relation to taxes of other Parties included in one of the following categories listed in Article 2, paragraph 1.b:

i: taxes on income, profits, capital gains or net wealth which are imposed on behalf of political divisions or local authorities of a Party;

iii: A. estate, inheritance or gift tax;

iii: D. specific taxes on goods and services such as excise taxes;

iii: F. taxes on the use or ownership of movable property other than motor vehicles;

iii: G. any other taxes.

Period covered: 01/08/2013 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 5 April 2013 — Or. Spa./Engl.

Pursuant to Article 30, paragraph 1.b, of the Convention, Costa Rica reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

Period covered: 01/08/2013 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 5 April 2013 — Or. Spa./Engl.

Pursuant to Article 30, paragraph 1.c, of the Convention, Costa Rica reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made under sub-paragraph a or b above, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

Period covered: 01/08/2013 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 5 April 2013 — Or. Spa./Engl.

Pursuant to Article 30, paragraph 1.d, of the Convention, Costa Rica reserves the right not to provide assistance in the service of documents for all taxes.

Period covered: 01/08/2013 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 5 April 2013 — Or. Spa./Engl.

Pursuant to Article 30, paragraph 1.e, of the Convention, Costa Rica reserves the right not to permit the service of documents though the post as provided for in paragraph 3 of Article 17.

Period covered: 01/08/2013 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretary General of the OECD on 5 April 2013 — Or. Spa./Engl.

Pursuant to Article 30, paragraph 1.f, of the Convention, Costa Rica reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

Period covered: 01/08/2013 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited with the Secretary General of the OECD on 5 April 2013 — Or. Spa./Engl.

ANNEX B — Competent authorities

The Director of the Tax Administration (Director General de Tributación ).

Period covered: 01/08/2013 -

Articles concerned: 3

Declarations transmitted by the Permanent Delegation of Costa Rica to the OECD to the Secretariat General of the OECD on 9 November 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 09/11/2018 -

Articles concerned: 28

Croatia

Reservation contained in the instrument of ratification deposited on 28 February 2014 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Croatia reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b, of the Convention:

i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

ii. compulsory social security contributions payable to general government or to social security institutions established under public law;

iii. A. estate, inheritance or gift taxes,

iii. B. taxes on immovable property,

iii. D. specific taxes on goods and services such as excise taxes,

iii. E. taxes on the use or ownership of motor vehicles,

iii. F. taxes on the use or ownership of movable property other than motor vehicles;

iv. Taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Croatia reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for taxes listed in the reservation made under Article 30, paragraph 1.a, of the Convention.

Pursuant to Article 30, paragraph 1.c, of the Convention, the Republic of Croatia reserves the right not to provide assistance in respect of any tax claim, which is in existence at the date of entry into force of the Convention in respect of the Republic of Croatia, or, if the tax claim is in relation to taxes which are listed in the reservation made under Article 30, paragraph 1. a or b of the Convention, at the date of withdrawal of such a reservation by the Republic of Croatia.

Pursuant to Article 30, paragraph 1.d, of the Convention, the Republic of Croatia reserves the right not to provide assistance in the service of documents for the taxes in the reservation made under Article 30, paragraph 1.a, of the Convention.

Pursuant to Article 30, paragraph 1.f, of the Convention, the Republic of Croatia reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of Croatia, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Republic of Croatia.

Period covered: 01/06/2014 -

Articles concerned: 30

Declaration contained in the instrument of ratification deposited on 28 February 2014 — Or. Engl.

ANNEX A — Existing taxes to which the Convention shall apply:

For the Republic of Croatia, the Convention shall apply to those taxes in Article 2, paragraph 1, of the Convention which fall within:

Article 2, paragraph 1.a.i:

• tax on income (porez na dohodak);
• tax on profits (porez na dobit).

Article 2, paragraph 1.b.iii:

C: — value-added Tax (porez na dodanu vrijednost);

G: — real estate transaction tax (porez na promet nekretnina).

Period covered: 01/06/2014 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited on 28 February 2014 — Or. Engl.

ANNEX B — Competent Authorities

In relation to the Republic of Croatia, the term «competent authority» means the Ministry of Finance or its authorised representative.

Period covered: 01/06/2014 -

Articles concerned: 3

Cyprus

Declaration contained in a Note verbale from the Permanent Representation of Cyprus handed over to the Deputy Secretary General of the Council of Europe at the time of signature of the instrument, on 10 July 2014 — Or. Engl., and confirmed in a Note verbale from the Permanent Representation of Cyprus, dated 16 December 2014, deposited with the instrument of ratification on 19 December 2014 — Or. Engl.

ANNEX A — Existing taxes to which the Convention shall apply

Article 2, paragraph 1.a.i:

• income tax;
• corporate income tax;
• special contribution for the defence of the Republic;

Article 2, paragraph 1.a.ii:

• capital gains tax.

Article 2, paragraph 1.b.iii:

B. Tax on Immovable Property;

C. Value Added Tax.

Period covered: 01/04/2015 -

Articles concerned: 2

Declaration contained in a Note verbale from the Permanent Representation of Cyprus handed over to the Deputy Secretary General of the Council of Europe at the time of signature of the instrument, on 10 July 2014 — Or. Engl., and confirmed in a Note verbale from the Permanent Representation of Cyprus, dated 16 December 2014, deposited with the instrument of ratification on 19 December 2014 — Or. Engl.

ANNEX B — Competent Authorities

The Minister of Finance or his autorised representative.

Period covered: 01/04/2015 -

Articles concerned: 3

Declaration contained in a Note verbale from the Permanent Representation of Cyprus handed over to the Deputy Secretary General of the Council of Europe at the time of signature of the instrument, on 10 July 2014 — Or. Engl., and confirmed in a Note verbale from the Permanent Representation of Cyprus, dated 16 December 2014, deposited with the instrument of ratification on 19 December 2014 — Or. Engl.

ANNEX C — Definition of the word «national» for the purposes of the Convention

i. any individual possessing the citizenship of Cyprus;

ii. any legal person, partnership or association deriving its status as such from the laws in force in the Republic of Cyprus.

Period covered: 01/04/2015 -

Articles concerned: 3

Reservation contained in a Note verbale from the Permanent Representation of Cyprus handed over to the Deputy Secretary General of the Council of Europe at the time of signature of the instrument, on 10 July 2014 — Or. Engl., and confirmed in a Note verbale from the Permanent Representation of Cyprus, dated 16 December 2014, deposited with the instrument of ratification on 19 December 2014 — Or. Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Cyprus will not provide any form of assistance in relation to the following taxes of other Parties described in Article 2, paragraph 1.b:

Sub-paragraph b.i: Taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

Sub-paragraph b.ii: Compulsory social security contributions payable to general government or to social security institutions established under public law;

Sub-paragraph b.iii: Taxes in other categories, except customs duties, imposed on behalf of a Party, namely:

A. estate, inheritance or gift taxes;

D. specific taxes on goods and services such as excise taxes;

E. taxes on the use or ownership of motor vehicles;

F. taxes on the use or ownership of movable property other than motor vehicles;

G. any other taxes;

Sub-paragraph b.iv: Taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

Period covered: 01/04/2015 -

Articles concerned: 30

Reservation contained in a Note verbale from the Permanent Representation of Cyprus handed over to the Deputy Secretary General of the Council of Europe at the time of signature of the instrument, on 10 July 2014 — Or. Engl., and confirmed in a Note verbale from the Permanent Representation of Cyprus, dated 16 December 2014, deposited with the instrument of ratification on 19 December 2014 — Or. Engl.

Pursuant to Article 30, paragraph 1.b, of the Convention, the Republic of Cyprus will not provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

Period covered: 01/04/2015 -

Articles concerned: 30

Declaration contained in a Note verbale from the Permanent Representation of Cyprus handed over to the Deputy Secretary General of the Council of Europe at the time of signature of the instrument, on 10 July 2014 — Or. Engl., and confirmed in a Note verbale from the Permanent Representation of Cyprus, dated 16 December 2014, deposited with the instrument of ratification on 19 December 2014 — Or. Engl.

Pursuant to Article 29, paragraph 1, of the Convention, the term Cyprus means the Republic of Cyprus and, when used in a geographical sense, includes the national territory, the territorial sea thereof as well as any area outside the territorial sea, including the contiguous zone, the exclusive economic zone and the continental shelf, which has been or may hereafter be designated, under the laws of Cyprus and in accordance with international law, as an area within which Cyprus may exercise sovereign rights or jurisdiction.

Period covered: 01/04/2015 -

Articles concerned: 29

Objection contained in a Note verbale from the Permanent Representation of Cyprus, dated 16 December 2014, deposited with the instrument of ratification on 19 December 2014 — Or. Engl.

The Republic of Cyprus objects to the declaration deposited by the Republic of Turkey at the time of signature of the instrument on 3 November 2011, limiting the implementation of the provisions of the Convention and the Protocol only to the States with which the Republic of Turkey has diplomatic relations. The aforesaid declaration is contrary to the object and purpose of the Convention as it precludes the realization of the cooperation foreseen by the Convention between all member States of the Council of Europe, one of which is the Republic of Cyprus, and, as such, the said reservation is invalid

Period covered: 01/04/2015 -

Articles concerned: -

Objection contained in a Note verbale from the Ministry of Foreign Affairs of Cyprus, dated 11 September 2015, registered at the Secretariat General on 14 September 2015 — Or. Engl.

The Republic of Cyprus objects to the declaration of the Republic of Azerbaijan dated 23 may 2014 and registered at the Secretariat General of the OECD on 23 September 2014, limiting the implementation of the provisions of the Convention and Protocol only to the States with which the Republic of Azerbaijan has diplomatic relations. The aforesaid declaration is contrary to the object and purpose of the Convention as it precludes the realisation of the cooperation foreseen by the Convention between all member States of the Council of Europe, one of which is the Republic of Cyprus, and as such, the said reservation is invalid.

Period covered: 14/09/2015 -

Articles concerned: -

Objection contained in a Note verbale from the Permanent Representation of Cyprus, dated 25 February 2016, registered at the Secretariat General on 29 February 2016 — Or. Engl.

The Republic of Cyprus objects to the declaration of the Republic of Azerbaijan dated 23 May 2014, registered at the Secretariat General of the OECD on 23 September 2014 and confirmed at the time of ratification of the Protocol on 29 May 2015, limiting the implementation of the provisions of the Convention and Protocol only to the States with which the Republic of Azerbaijan has diplomatic relations. The aforesaid declaration is contrary to the object and purpose of the Convention as it precludes the realisation of the cooperation foreseen by the Convention between all member States of the Council of Europe, one of which is the Republic of Cyprus, and as such, the said reservation is invalid.

Period covered: 29/02/2016 -

Articles concerned: -

Declaration transmitted by the Embassy of Cyprus in Paris to the Secretariat General of the OECD on 12 October 2018 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 12/10/2018 -

Articles concerned: 28

Objection contained in a Note Verbale from the Permanent Representation of Cyprus, dated 19 March 2019, registered at the Secretariat General of the Council of Europe on 26 March 2019 — Or. Engl.

The Republic of Cyprus has examined the Declaration contained in the instrument of ratification deposited by the Republic of Turkey with the Secretary General of the OECD on 26 March 2018, upon ratification of the Convention on Mutual Administrative Assistance in Tax Matters of 25th January 1988, (No. 127).

The Republic of Turkey declares that its ratification of the Convention on Mutual Administrative Assistance in Tax Matters of 25th January 1988, (No. 127) neither amounts to any form of recognition of the Republic of Cyprus, as party to that Convention, nor should it imply any obligation on the part of the Republic of Turkey to enter into any dealing with the Republic of Cyprus within the framework of the said Convention.

In the view of the Republic of Cyprus, the content and purported effect of this Declaration makes it tantamount in its essence to a reservation contrary to the object and purpose of the Convention. By such Declaration, the Republic of Turkey purports to evade its obligations under the Convention vis — à - vis another equal and sovereign State Party, namely the Republic of Cyprus. Indeed, the Declaration prevents the realization of cooperation between State Parties foreseen by the Convention.

The Republic of Cyprus therefore strongly rejects the aforesaid Declaration made by the Republic of Turkey and considers such declaration to be null and void. The aforementioned objections by the Republic of Cyprus shall not preclude the entry into force of the Convention, in their entirety, between the Republic of Cyprus and the Republic of Turkey.

Regarding the Republic of Turkey's pretension, as expressed in the same Declaration, that «the Republic of Cyprus is defunct and that there is no single authority which in law or in fact is competent to represent jointly the Turkish Cypriots and the Greek Cypriots and consequently Cyprus as a whole», the Republic of Cyprus would like to remind of the following:

Despite, being, through binding international agreements, a guarantor of «the independence, territorial integrity and security of the Republic of Cyprus» (Article II of the 1960 Treaty of Guarantee), the Republic of Turkey illegally invaded Cyprus in 1974 and continues since then occupying 36.2% of the territory of the Republic.

The illegality of such aggression was made manifested by the U.N. Security Council Resolutions 541 (1983) and 550 (1984). Resolution 541's operative paragraph 2 considers «the declaration [of the Turkish Cypriot authorities of the purported secession of part of the Republic of Cyprus] as legally invalid and „calls for its withdrawal“. Paragraph 6 then „calls upon all States to respect the sovereignty, independence, territorial integrity and non-alignment of the Republic of Cyprus“ and further at par. 7 „calls upon all States not to recognize any Cypriot state other than the Republic of Cyprus“. Resolution 550, operative para. 2, also „condemns all secessionist actions, including the purported exchange of Ambassadors between Turkey and the Turkish Cypriot leadership, declares them illegal and invalid, and calls for their immediate withdrawal“. Para. 3 then „reiterates the call upon all States not to recognize the purported state of the „Turkish Republic of Northern Cyprus“ set up by secessionist acts and calls upon them not to facilitate or in any way assist the aforesaid secessionist entity».

The European Court of Human Rights additionally, in its Judgment of 10th May 2001 on the Fourth Interstate Application of Cyprus v. Turkey, found, at para. 77, that Turkey, which has «effective control over northern Cyprus», is responsible for securing all human rights under the European Convention on Human Rights and for violations of such rights by her own soldiers or officials, or by the local administration, which are imputable to Turkey. The responsibilities of the occupying power emanate from international humanitarian law, including the Fourth Geneva Convention.

Turkey is responsible for the policies and actions of the «TRNC» because of the effective control she exercises through her army. Her responsibility is engaged by virtue of the acts of the local administration, which survives by virtue of Turkish military and other support (Cyprus v. Turkey, Judgment, 10 May 2001, at pp. 20-21, reiterating Loizidou). From the judgments of the European Court of Human Rights and the Security Council Resolutions on Cyprus, it is evident that the international community does not regard the «TRNC» (Turkey's subordinate local administration in occupied Cyprus, condemned in the strongest terms by the Security Council) as a State under international law (Cyprus v. Turkey, 10 May 2001, para. 61). In contrast, the Republic of Cyprus has repeatedly been held to be the sole legitimate Government of Cyprus, contrary to Turkey's assertions about that Government, which Turkey calls «the Greek Cypriot Administration» with pretences «to represent the defunct Republic». The Turkish assertions constitute a propaganda ploy to divert attention from Turkey's responsibility for the violations in occupied Cyprus. Turkey's assertions and her assorted objections to the Republic of Cyprus' authority, jurisdiction and sovereignty, and her claims on behalf of the Turkish Cypriots and the «TRNC», have repeatedly been rejected by the international community and relevant judicial bodies where such claims were fully argued and then rejected in Cyprus's pleadings. Misrepresentations about the treatment of Turkish Cypriots by the Government of Cyprus were made. (These claims were repeated in Turkey's current Declaration). In fact, the European Court of Human Rights and the Commission accepted Cyprus arguments and refutation of Turkish assertions and exaggerations about the period prior to Turkey's invasion of Cyprus in July 1974. It refused to pronounce on Turkey's version of the ejection of Turkish Cypriots from offices of State (there was in fact a Turkish boycott).

It is now time for the relevant pronouncement in Resolutions and the decisions therein, as well as in judgments of the European Court of Human Rights to be heard and acted upon. The Court itself insisted in its 12 May 2014 Just Satisfaction Judgment that this must happen once the Court had spoken (Cyprus v. Turkey, p. 23 Joint Concurring Judgment of nine Judges). It should be emphasized that, the Security Council repeatedly reaffirmed all its relevant Resolutions on Cyprus, having, over several decades and reiterated their content.

Nevertheless, the Republic of Turkey, not only flagrantly holds in contempt all relevant U.N. Resolutions, International Law rules and the U.N. Charter on the matter, but furthermore she continues violating international legality, by systematically questioning the legitimacy of the Republic of Cyprus and further promoting the illegal secessionist entity in the occupied part of the Republic of Cyprus, including through declarations, as the one at hand.

Period covered: 26/03/2019 -

Articles concerned: -

Czech Republic

Declaration contained in a Note verbale from the Permanent Representation of the Czech Republic to the Council of Europe, dated 6 October 2020, registered at the Secretariat General on 9 October 2020 — Or. Engl.

In accordance with Article 2, paragraph 3, of the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 Protocol (hereinafter «the Convention»), the Czech Republic notifies the new wording of the part of the Annex A that concerns taxes to which the Convention shall apply under its Article 2, paragraph 1.a.i. The new wording of the above-mentioned part of the Annex A is:

Annex A — Taxes to which the Convention would apply

Article 2, paragraph 1.b.iii.D:

- Excise duty on mineral oils, on ethyl alcohol, on beer, on wine and intermediate products and on tobacco products, tax on heated tobacco products, tax on raw tobacco, tax on natural gas and some other gases, tax on solid fuels, tax on electricity.

Period covered: 01/02/2021 -

Articles concerned: 2

Declaration transmitted by a Note Verbale from the Permanent Representation of the Czech Republic to the Secretary General of the Council of Europe on 15 March 2019 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 15/03/2019 -

Articles concerned: 28

Declaration transmitted by a Note Verbale from the Permanent Representation of the Czech Republic to the Secretary General of the Council of Europe on 15 March 2019 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Period covered: 15/03/2019 -

Articles concerned: 28

Declaration contained in a Note Verbale from the Permanent Representation of the Czech Republic to the Council of Europe, dated 8 February 2019, registered at the Secretariat General on 12 February 2019 — Or. Engl.

In accordance with Article 2, paragraph 3, of the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 Protocol (hereinafter «the Convention»), the Czech Republic notifies the new wording of the part of the Annex A that concerns taxes to which the Convention shall apply under its Article 2, paragraph 1.a.i.

The new wording of the above-mentioned part of the Annex A is:

Article 2, paragraph 1.a.i.:

• Personal income tax;
• Corporation income tax;
• Gambling tax;

Period covered: 01/06/2019 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited on 11 October 2013 — Or. Engl.

ANNEX B — Competent Authorities

The Minister of Finance or his authorised representative; The Czech Social Security Administration in relation to compulsory social security contributions and a contribution to the state employment policy; The Center for International Reimbursements in relation to compulsory public health insurance contributions.

Period covered: 01/02/2014 -

Articles concerned: 3

Interpretative declaration contained in the instrument of ratification deposited on 11 October 2013 — Or. Engl.

The Czech Republic, in order to ensure unequivocal interpretation of Article 22, paragraph 2, of the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 Protocol, declares that it interprets Article 22, paragraph 2, of the Convention as amended by the 2010 Protocol, as not establishing any automatic right of the requesting State to use information received in accordance with the Convention as amended by the Protocol as evidence in criminal proceedings, but information received in accordance with the Convention as amended by the Protocol may be used by the requesting State in criminal proceeding as evidence only if judicial authorities of the requested State or any other authorities of the requested State competent under the laws of the requested State give consent to it in accordance with applicable international treaties on mutual legal assistance in criminal matters and the domestic law of the requested State concerning providing mutual legal assistance in criminal matters.

Period covered: 01/02/2014 -

Articles concerned: 22

Declaration contained in the instrument of ratification deposited on 11 October 2013 — Or. Engl.

ANNEX A — Existing taxes to which the Convention shall apply:

[<*> Article 2, paragraph 1.a.i:

• Personal income tax

- Corporate income tax

- Levy on lotteries and other similar games]

Article 2, paragraph 1.b.ii:

• Public health insurance and social security insurance and a contribution to the state employment policy

Article 2, paragraph 1.b.iii.B:

• Real estate tax, tax on acquisition of real estate

Article 2, paragraph 1.b.iii.C:

• Value-added Tax

[<**> Article 2, paragraph 1.b.iii.D:

• Excise duty on mineral oils, on ethyl alcohol, on beer, on wine and intermediate products and on tobacco products, tax on natural gas and some other gases, tax on solid fuels, tax on electricity.]

Article 2, paragraph 1.b.iii.E:

• Road tax.

[Notes by the Secretariat:

<*> This part of the 2014 Declarations has been replaced as of 1 June 2019. See the Declaration dated 12 February 2019.

<**> This part of the 2014 Declarations has been replaced as of 1 February 2021. See the Declaration dated 9 october 2020.]

Period covered: 01/02/2014 -

Articles concerned: 2

Denmark

Declaration contained in the instrument of approval, deposited on 16 July 1992 — Or.Engl.

As regards Denmark, the Convention shall apply to the territory of the Kingdom of Denmark including the territorial sea of Denmark as well as any other maritime area to the extent that that area, in accordance with international law, has been or may hereafter be designated under Danish laws as an area within which Denmark may exercise sovereign rights for the purpose of exploring and exploituing the natureal resources of the seabed or its sub-soil and the superjacent waters and with regard to other activities for the exonomic exploration and exploitation of the area; for the purpose of this Convention the term also includes the autonomous regions within the Kingdom of Denmark of Greenland and the Faroe Islands.] (*)

[(*) Note by the Secretariat: Declaration amended as from 1 January 2007 — See the declarations registered on 10 November 2006 and 16 February 2007. The original declaration read (..) the term also includes the autonomous region within the Kingdom of Denmark of Greenland.]

Period covered: 01/04/1995 -

Articles concerned: 29

Declaration contained in the instrument of approval, deposited on 16 July 1992 — Or.Engl.

ANNEX B

DENMARK (except for Greenland)

The Minister for Taxation of his authorised representative,

GREENLAND

The Local Government or its authorised representative.

Period covered: 01/04/1995 -

Articles concerned: 3

Declaration transmitted by a letter from the Deputy Head of the Danish OECD-Delegation in Paris, dated 28 September 2001, registered by the Secretariat General of the OECD on 28 September 2001 — Or. Engl.

The Convention will continue to apply to taxes that have been repealed or renamed as long as the taxes remain enforceable and collectible.

ANNEX A (Tax covered)

Danish taxes:

Article 2, paragraph 1.a:

i.: income taxes to the State (indkomstskatter til staten)

ii.: --

iii.: capital tax to the State (formueskat til staten) — repealed as of 1 January 1997, enforceable and collectible until 1 January 2002 (in cases of fraud until 1 January 2017)

Article 2, paragraph 1.b:

i.: income tax to the municipalities (kommunal indkomstskat),

income tax to the county municipalities (amtskommunal indkomstskat),

tax on immovable property (ejendomsskat);

tax on assessed value of immovable property ( ejendomsværdiskat ),

church tax (kirkeskat)

ii.: labour market contribution (arbejdsmarkedsbidrag),

special pension contribution ( særligt pensionsbidrag)

iii. A: tax on inheritance and gifts (afgift af dødsboer og gaver)

iii. B: --

iii. C: value added tax ( merværdiafgift ),

iii. D: excise duties imposed by the State (forbrugsafgifter, som pålægges af staten)

iii. E: registration tax on motor vehicles (registreringsafgift af motorkøretøjer ),

weight tax on motor vehicles and other taxes on the ownership or use of motor vehicles ( vægtafgift af motorkøretøjer og andre afgifter på oje eller brug af motorkøretøjer )

iii. F: tax on insurances for yachts (afgift af lystfartøsforsikringer )

iii. G: payroll tax ( lømsumsafgift ),

taxes on betting, on casinos and on lottery prizes (afgift af totalisatorspil, spillekasinoer og gevinster ved lotterispil),

tax on registration of rights in real property etc. (afgift af tinglysning og registrering af cjer- og pantrettigheder),

stamp duty (stempelafgift)

iv.: service charge on business property ( dækningsafgift af forretningsejendom),

property release tax ( frigørelsesafgift )

Greenlandic taxes:

Article 2, paragraph 1.a.

i.: income tax to the Greelandic home rule Government (landsskat, særlig landsskat),

dividend tax (udbytteskat),

company tax (selskabsskat)

Article 2, paragraph 1.b.

i.: municipal tax (kommuneskat),

common municipal tax ( fælleskommunal skat),

dividend tax (udbytteskat);

company tax (selskabsskat)

ii.: employer's contributions to vocational training (arbejdsgivernes erhvervsuddannelsesbidrag)

iii. A: tax on inheritance and gifts (afgift af arv og gave)

iii. C: import duty ( indførselsafgift )

iii. D: tax on gambling machines (afgift af automatspil),

harbour duty (havneafgift),

tax on sea transport of goods to, from and within Greenland (afgift på søtransport af gods til, fra og I Grønland ),

tax on shrimps (afgift på rejer)

iii. E: tax on motor vehicles (afgift af motorkøretøjer )

iii. G: tax on lottery (lotteriafgift),

stamp duty (stempelafgift).

Period covered: 01/01/2002 -

Articles concerned: 2

Declaration contained in a letter from the Ambassador of Denmark to OECD, dated 26 September 2006, transmitted by the Secretariat General of OECD on 18 October 2006 and registered at the Secretariat General on 10 November 2006 — Or. Engl.

Denmark withdraws its declaration with respect of Faroe Islands made in connection with the ratification of the Convention. It is decided that the Convention will also be applicable in Faroe Islands from 1 January 2007. Annexes A and B to the Convention are accordingly supplemented.

Period covered: 01/01/2007 -

Articles concerned: 29

Declaration contained in a letter from the Ambassador of Denmark to OECD, dated 26 September 2006, transmitted by the Secretariat General of OECD on 18 October 2006 and registered at the Secretariat General on 10 November 2006 — Or. Engl.

Annex B — Competent Authority

FAROE ISLANDS

The Faroe Islands Customs and Tax Administration (Toll- og Skattstova Føroya ).

Period covered: 01/01/2007 -

Articles concerned: 3

Declaration contained in a letter from the Ambassador of Denmark to OECD, dated 26 September 2006, transmitted by the Secretariat General of OECD on 18 October 2006 and registered at the Secretariat General on 10 November 2006 — Or. Engl.

ANNEX A (Tax covered)

Faroese taxes

Article 2, paragraph 1. a:

i.: income taxes to the Faroese home rule Government (landsskattur)

royalty taxes (skattur av nýtslugjaldi )

taxes levied under the Hydrocarbon Tax Act (skattur eftier kolvetnisskattalógini )

taxes levied under the Tonnage Tax Act (skattur eftir tonnsaskattalógini )

ii.: taxes levied under the Act on Taxation of Capital Gains (kapitalvinningsskattur)

Article 2, paragraph 1.b:

i.: income taxes to the municipalities (komunuskattur)

church tax (kirkjuskattur)

ii.: labour market contribution (ALS-gjald)

special pension contribution ( arbeiðsmarknareftirlønargjald )

iii. C: value added tax ( meirvirðisgjald )

iii. D: import and excise duties (tollur)

iii. E: registration tax on motor vehicles ( skrásetingargjald )

weight tax on motor vehicles and other taxes on the ownership or use of motor vehicles (veggjald)

iii. G: Tax on registration of rights in real property ( tinglýsingargjald )

Period covered: 01/01/2007 -

Articles concerned: 2

Declaration contained in a letter from the Ambassador of Denmark to OECD, dated 2 February 2007, transmitted by the Director of Legal Affairs of the OECD by a letter dated 12 February 2007 and registered by the Secretariat General on 16 February 2007 — Or. Engl.

With reference to the instrument of approval of the Convention by Denmark, which was deposited with the Council of Europe on 16 July 1992, Denmark's notification of 26 September 2006 and OECD's reply of 18 October 2006, concerning the withdrawal by Denmark of its declaration with respect to Faroe Islands made in connection with the approval of the said instrument, the Convention is also applicable in Faroe Islands from 1 January 2007.

Therefore, the last sentence of the declaration contained in the instrument of approval deposited on 16 July 1992 should read as follows: «(...) the term also includes the autonomous regions within the Kingdom of Denmark of Greenland and the Faroe Islands.»

Period covered: 01/01/2007 -

Articles concerned: 29

Declaration transmitted by the Delegation of Denmark to the OECD to the Secretariat General of the OECD on 5 April 2017 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 05/04/2017 -

Articles concerned: 28

Dominica

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 30 April 2019 — Or. Engl.

ANNEX A — Taxes to which the Convention would Apply

Article 2, paragraph 1.a.i:

. Personal Income Tax;

. Corporate Tax;

. Withholding Tax.

Article 2, paragraph 1.b.iii.B: Land Transfer Fees.

Article 2, paragraph 1.b.iii.C: Value Added Tax.

Article 2, paragraph 1.b.iii.D: Excise Tax.

Article 2, paragraph 1.b.iii.E:

. Motor Vehicle License Fees;

. Highway Maintenance Levy.

Article 2, paragraph 1.b.iii.G:

. Stamp Duties;

. Import Duties.

Period covered: 01/08/2019 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD on 30 April 2019 — Or. Engl.

ANNEX B — Competent authorities

The Minister for Finance or its authorised representative.

Period covered: 01/08/2019 -

Articles concerned: 3

Declaration transmitted by a Note Verbale from the Embassy of the Commonwealth of Dominica to the European Union, dated 15 May 2019, registered at the Secretariat General of the OECD on 20 May 2019 — Or. Engl.

Declaration on the effective date for exchanges of information under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

Period covered: 01/08/2019 -

Articles concerned: 28

Dominican Republic

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

Annex A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i: Taxes on profits, capital or equity gains of natural or legal persons.

Article 2, paragraph 1.b.iii.A: Taxes on property, inheritance or donations.

Article 2, paragraph 1.b.iii.B: Taxes on real estate.

Article 2, paragraph 1.b.iii.C: General consumption taxes.

Article 2, paragraph 1.b.iii.D: Specific taxes on goods and services.

Period covered: 01/12/2019 -

Articles concerned: 2

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

Annex B — Competent authorities

The Minister of Finance or his authorised representative.

Period covered: 01/12/2019 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

Annex C — Definition of the term «nationals»

In relation to the Dominican Republic, the term «national» means any citizen and any legal entity or any other collective entity, whose existence derives from the current laws in each of the Parties.

Regarding the definition of «national», the Dominican Republic points out that it recognizes citizens with dual nationalities, meaning the Dominican citizen who, by any legal means, acquires a secondary nationality and still maintains the Dominican nationality for our legal purposes. This definition is intended to include Dominican nationals in every country in which their Dominican nationality is legally recognized. If the other Party does not recognize dual nationality, the term should only apply to the extent of the Dominican Republic.

Period covered: 01/12/2019 -

Articles concerned: 3

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

Pursuant to Article 9, paragraph 3, of the Convention, the Dominican Republic declares its intention not to accept, as a general rule, such requests as are referred to in Article 9, paragraph 1, of the Convention.

Period covered: 01/12/2019 -

Articles concerned: 9

Declaration contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

In accordance with Article 29, paragraph 1, of the Convention, the Dominican Republic declares that, with respect to it, the Convention will apply to the entire territory of the Dominican Republic, using the geographical sense, which includes the eastern part of the island of Santo Domingo, its adjacent islands and the set of natural elements of its marine geomorphology. Its irreducible land limits are set by the 1929 Border Treaty and its 1936 Revision Protocol. In addition, it includes the corresponding territorial sea, sea floor and subsoil, as well as the continuous zone, exclusive economic zone and the continental shelf; it also contains the airspace over the national territory, the electromagnetic spectrum and the space where it acts, in accordance with its legislation and international law.

Period covered: 01/12/2019 -

Articles concerned: 29

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

In accordance with Article 30, paragraph 1.a, of the Convention, the Dominican Republic reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in one of the following categories listed in Article 2, paragraph 1.b:

i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

ii. compulsory social security contributions payable to the general government or social security institutions established under public law;

iii. taxes on the use or ownership of motor vehicles;

iv. taxes on the use or ownership of movable property other than motor vehicles;

v. any other taxes;

vi. taxes in categories other than those referred to in number i and ii, which are imposed on behalf of political subdivisions or local authorities of a Party.

Period covered: 01/12/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

In accordance with Article 30, paragraph 1.b, of the Convention, the Dominican Republic reserves the right not to provide assistance in the collection of any tax claim, or in the recovery of an administrative fine, for all taxes.

Period covered: 01/12/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

In accordance with Article 30, paragraph 1.c, of the Convention, the Dominican Republic reserves the right not to provide assistance in respect of any tax claim which is in existence at the date of entry into force of the Convention with respect to that State or, where a reservation has previously been made under sub-paragraphs a or b of paragraph 1 of Article 30, at the date of withdrawal of such a reservation in relation to taxes in the category in question.

Period covered: 01/12/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

In accordance with Article 30, paragraph 1.d, of the Convention, the Dominican Republic reserves the right not to provide assistance in the service of documents, for all taxes.

Period covered: 01/12/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

In accordance with Article 30, paragraph 1.e, of the Convention, the Dominican Republic reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.

Period covered: 01/08/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD, on 2 August 2019 — Or.Span./Engl.

In accordance with Article 30, paragraph 1.f, of the Convention, the Dominican Republic reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Dominican Republic, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of the Dominican Republic.

Period covered: 01/12/2019 -

Articles concerned: 28, 30

Ecuador

Declaration contained in a Declaration from the Minister of Foreign Affairs of Ecuador handed over to the Secretariat General of OECD at the time of signature of the instrument, on 29 October 2018 — Or. Engl. and confirmed at the time of deposit of the instrument of ratification, on 26 August 2019 — Or. Engl.

ANNEX B — Competent authorities

The Director of the Internal Revenue Service or its authorised representative.

Period covered: 01/12/2019 -

Articles concerned: 3

Reservation contained in a Note Verbale from the Embassy of Ecuador in France and in the instrument of ratification, deposited with the Secretariat General of the OECD on 26 August 2019 — Or. Spa./Engl.

Pursuant to Article 30, paragraph 1.a, of the Convention, the Republic of Ecuador reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b, of the Convention:

i. taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

ii. compulsory social security contributions payable to the general government or social security institutions established under public law;

vi. taxes in categories referred to in sub-paragraph iii which are imposed on behalf of political subdivisions or local authorities of a Party.

Period covered: 01/12/2019 -

Articles concerned: 2, 30

Reservation contained in a Note Verbale from the Embassy of Ecuador in France and in the instrument of ratification, deposited with the Secretariat General of the OECD on 26 August 2019 — Or. Spa./Engl.

In accordance with Article 30, paragraph 1.e, of the Convention, the Republic of Ecuador reserves the right not to permit the service of documents through the post as provided for in paragraph 3 of Article 17.

Period covered: 01/12/2019 -

Articles concerned: 17, 30

Declaration contained in a Note Verbale from the Embassy of Ecuador in France and in the instrument of ratification, deposited with the Secretariat General of the OECD on 26 August 2019 — Or. Spa./Engl.

ANNEX A — Taxes to which the Convention would apply

Article 2, paragraph 1.a.i:

Income tax (impuesto a la renta)

Participation of labour in profits of mining rights holders, attributable to the State ( participación laboral en las utilidades de titulares de derechos mineros, atribuibles al Estado)

Mineral exploitation royalties ( Regalías a la explotación de minerales)

Adjustment required to comply with Article 408 of the Constitution, applicable to the exploitation of non-renewable natural resources (Ajuste necesario para cumplir con lo dispuesto en el artículo 408 de la Constitución , correspondiente a la explotación de recursos naturales no renovables)

Article 2, paragraph 1.a.ii:

Income tax on gains from the alienation of shares, participations, other rights in the capital of entities, or other exploration, exploitation, concession or similar rights (Impuesto a la renta único a la utilidad en la enajenación de acciones, participaciones, otros derechos representativos de capital u otros derechos que permitan la exploración , explotación , concesión o similares)

Article 2, paragraph 1.a.iii:

Tax on assets held abroad (Impuesto a los activos en el exterior)

Article 2, paragraph 1.b.iii.A:

Income tax on worth increases from inheritances, estates, gifts, findings and similar sources (Impuesto a la renta por incrementos patrimoniales provenientes de herencias, legados, donaciones, hallazgos y otros de naturaleza análoga )

Article 2, paragraph 1.b.iii.C:

Value added tax (Impuesto al valor agregado IVA).

Article 2, paragraph 1.b.iii.D:

Special consumption tax (impusto a los consumos especiales ICE)

Article 2, paragraph 1.b.iii.E:

Tax on the ownership of motor vehicles (Impuesto a la propriedad de vehículos motorizados)

Article 2, paragraph 1.b.iii.G:

Ecuadorian simplified tax regime (Regimen impositivo simplificado ecuatoriano RISE)

Currency outflow tax (Impuesto a la salida de divisas ISD)

Redeemable tax on nonreturnable plastic bottles (Impuesto redimible a las botellas plásticas no retornables)

Mining concession conservation patents (Patentes de conservación de concesiones mineras)

Period covered: 01/12/2019 -

Articles concerned: 2

Declaration contained in a Note Verbale from the Embassy of Ecuador in France and in the instrument of ratification, deposited with the Secretariat General of the OECD on 26 August 2019 — Or. Spa./Engl.

ANNEX C — Definition of the word «national» for the purpose of the Convention

In relation to the Republic of Ecuador, the term «national» means any individual possessing Ecuadorian nationality or citizenship and any legal person, association or other entity deriving its status as such from the laws in force in Ecuador.

Period covered: 01/12/2019 -

Articles concerned: 3

El Salvador

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 26 February 2019 — Or. Engl., and supplemented by a Note verbale from the Embassy of El Salvador in France, dated 20 May 2019, registered at the Secretariat General of the OECD on 21 May 2019 — Or. Fr.

Pursuant to Article 30, paragraph 1.a, of the Convention, El Salvador reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b:

i.: Taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

iii.A.: Estate, inheritance or gift taxes,

iii.F.: Taxes on the use or ownership of movable property other than motor vehicles,

iii.G.: Any other taxes;

iv.: Taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.

Period covered: 01/06/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 26 February 2019 — Or. Engl., and supplemented by a Note verbale from the Embassy of El Salvador in France, dated 20 May 2019, registered at the Secretariat General of the OECD on 21 May 2019 — Or. Fr.

Pursuant to Article 30, paragraph 1.b, of the Convention, El Salvador reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.

Period covered: 01/06/2019 -

Articles concerned: 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 26 February 2019 — Or. Engl., and supplemented by a Note verbale from the Embassy of El Salvador in France, dated 20 May 2019, registered at the Secretariat General of the OECD on 21 May 2019 — Or. Fr.

Pursuant to Article 30, paragraph 1.f, of the Convention, El Salvador reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

Period covered: 01/06/2019 -