Small Business/Self-Employed
International Taxpayers Topics
IRS Resources
Competent Authority Agreements |
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A Competent Authority Agreement is a bilateral agreement between the United States and the treaty partner to clarify or interpret treaty provisions.
Country |
Agreement |
Austria |
U.S. - Austria: Tax Treatment of Certain Scholarships. Mar. 1, 2005 (PDF)
U.S. - Austria : Taxing Deferred Payments to U.S. Citizens Residing in Austria. Aug. 27, 2003 (PDF) |
France |
U.S. - France: Taxation Of French Social Security. May 31, 2001 (PDF) |
India |
U.S. - India: Memorandum Of Understanding Regarding Deferment Of Assessment And/Or Suspension Of Collection Of Taxes During Mutual Agreement Procedure. Sept. 25, 2002 (PDF) |
Ireland |
U.S. - Ireland: Competent Authority Agreement regarding the income received by Irish unit holders in a Common Contractual Fund - February 9, 2006. (PDF) |
Japan |
U.S. - Japan: Guidance regarding the Commencement of Application of the new Tax Convention between the United States and Japan. Jun. 23, 2004 (PDF)
U.S. - Japan: The Competent Authorities of the United States and Japan Agree to the following Guidelines concerning the meaning of the term Investment Bank. Dec. 27, 2005 (PDF)
U.S. - Japan: Memorandum of Understanding - First Publication Concerning Notification of Self-Certification of U.S. and Japanese Resident Investment Banks. March 3, 2006 (PDF)
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Luxembourg |
U.S. – Luxembourg: Interpretation of Tax Treaty’s Transition Rules. Nov. 09, 2001 (PDF) |
Mexico |
U.S. - Mexico: Mutual Agreement Regarding Eligibility of Fiscally Transparent Entities to Benefits. Aug 26, 2005 (PDF)
U.S. - Mexico: Mutual Agreement Regarding Eligibility of Fiscally Transparent Entities to Benefits. Dec. 22, 2005 (PDF)
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Netherlands |
U.S. - Netherlands: Updated Agreement Identifying Pensions for Treaty Benefits August 13, 2007 (PDF)
U.S. - Netherlands: Administrative Arrangements for Mutual Agreement Procedure. Oct. 7, 2003 (PDF)
U.S. - Netherlands: Pensions Investing Through Hybrid entities. Mar. 21, 2003 (PDF)
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New Zealand |
U.S. - New Zealand: Mutual Agreement Regarding Treatment of Income Derived Through Certain Fiscally Transparent Entities. Feb. 10, 2005 (PDF) |
Spain |
U.S.- Spain Agreement Regarding Eligibility of Benefits to Fiscally Transparent Entities. Feb. 15, 2006 (PDF) |
Switzerland |
U.S. - Swiss: Pension Plans for Tax Treaty Benefits. Dec. 10, 2004 (PDF)
US – Swiss: Guidance on Treaty Benefits. Aug. 22, 2003 (PDF)
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United Kingdom |
U.S. - U.K. agreement defining the term "First Notification" under Treaty Article 26(1) - September 12, 2007 (PDF)
U.S. - U.K. Agreement Regarding Dual Consolidated Loss Rules. Oct. 6, 2006 (PDF)
U.S. - U.K.: Agreement Identifies U.K. Pension Arrangements for Tax Treaty Benefits. Apr. 13, 2005 (PDF)
U.S. - U.K.: New Administrative Arrangements for Mutual Agreement Procedure. Jan 00, 2000 (PDF)
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References/Related Topics
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