Competent Authority Arrangement Sample Contracts

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • October 28th, 2015

On September 12, 2012, the Government of the United States of America and the Government of United Kingdom of Great Britain and Northern Ireland signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and United Kingdom Reportable Accounts on an automatic basis, pursuant to the provisions of Article 27 of the Convention between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital Gains, signed at London on December 31, 1975 (“Convention”).

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COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • August 9th, 2021

The competent authorities of the United Kingdom and the United States enter into this arrangement (the “Arrangement”) regarding the interpretation of the term

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • April 19th, 2016

On July 31, 2015, the United States of America and the Slovak Republic signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the United States of America and the Slovak Republic to Improve International Tax Compliance and to Implement FATCA”. The IGA requires, in particular, the exchange of certain information with respect to U.S. and Slovak Reportable Accounts on an automatic basis, pursuant to the provisions of Article 27 of the Convention between the United States of America and the Slovak Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, done at Bratislava on October 8, 1993 (the "Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • November 9th, 2015

On November 17, 2014, the Government of the United States of America and the Government of Barbados signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of Barbados to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Barbados Reportable Accounts on an automatic basis, pursuant to the provisions of Article 26 of the Convention between the United States of America and Barbados for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, done at Bridgetown on December 31, 1984, as amended by the Protocols, done at Washington on December 18, 1991 and July 14, 2004, (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • June 3rd, 2016

On August 6, 2015, the Government of the United States of America and the Portuguese Republic signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the United States of America and the Portuguese Republic to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Portuguese Reportable Accounts on an automatic basis, pursuant to the provisions of Article 28 of the Convention between the United States of America and the Portuguese Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, together with a Related Protocol, done at Washington on September 6, 1994 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • March 8th, 2016

On May 20, 2015, the Government of the United States of America and the Government of the Republic of Colombia signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic of Colombia to Improve International Tax Compliance and to Implement the Automatic Exchange of Information with respect to FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Colombian Reportable Accounts on an automatic basis, pursuant to the provisions of Article 4 of the Agreement Between the Government of the United States of America and the Government of the Republic of Colombia for the Exchange of Tax Information, done at Bogota, March 20, 2001 (the “TIEA”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • February 18th, 2016

On January 10, 2014, the Government of the United States of America and the Government of the Republic of Italy signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of Republic of Italy to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Italian Reportable Accounts on an automatic basis, pursuant to the provisions of Article 26 of Convention between the Government of the United States of America and the Government of the Republic of Italy for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fraud or Fiscal Evasion, done at Washington on August 25, 1999 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • September 30th, 2015

On April 28, 2014, the Government of the United States of America and the Government of Australia signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of Australia to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Australian Reportable Accounts on an automatic basis, pursuant to the provisions of Article 25 of the Convention between the Government of the United States of America and the Government of Australia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • September 6th, 2016

On June 10, 2015, the United States of America and the Holy See, acting also in the name and on behalf of the Vatican City State signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the United States of America and the Holy See, Acting Also in the Name and on Behalf of the Vatican City State, to Improve International Tax Compliance and to Implement FATCA”. The IGA requires, in particular, the exchange of certain information with respect to U.S. Reportable Accounts on an automatic basis.

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • December 1st, 2015

On June 2, 2014, the Government of the United States of America and the Government of the Republic of Slovenia signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic of Slovenia to Improve International Tax Compliance and

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • February 16th, 2016

On March 31, 2014, the Government of the United States of America and the Government of the Republic of Honduras signed an intergovernmental agreement

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • September 15th, 2015

On January 23, 2013, the Government of the United States of America and the Government of Ireland signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of Ireland to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Irish Reportable Accounts on an automatic basis, pursuant to the provisions of Article 27 of the Convention between the Government of the United States of America and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed at Dublin on July 28, 1997 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • February 27th, 2020

On June 15, 2018, the Government of the United States of America and the Government of the Commonwealth of Dominica signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Commonwealth of Dominica to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. Reportable Accounts on an automatic basis.

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • January 19th, 2016

On April 15, 2013, the Government of the United States of America and the Government of the Kingdom of Norway signed an intergovernmental agreement (“IGA”) entitled, “Agreement Between the Government of the United States of America and the Government of the Kingdom of Norway to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Norwegian Reportable Accounts on an automatic basis, pursuant to the provisions of Article 28 of the Convention between the Government of the United States of America and the Government of the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • January 14th, 2016

On November 29, 2013, the Government of the United States of America and the Government of the Cayman Islands signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the Cayman Islands and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. Reportable Accounts on an automatic basis, pursuant to the provisions of Article 6 of the Tax Information Exchange Agreement between the United States and the Cayman Islands, signed in London, United Kingdom on November 29, 2013 (the “TIEA”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • August 9th, 2021

The competent authorities of the United States and the United Kingdom enter into this arrangement (the “Arrangement”) under the Convention between the United States of America and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital Gains signed at London on July 24, 2001, as amended by the Protocol signed on July 19, 2002 (the “Treaty”). The Arrangement is entered into under paragraph 3 of Article 26 (Mutual Agreement Procedure) of the Treaty.

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • September 24th, 2015

On May 26, 2015, the Government of the United States of America and the Government of Iceland signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of Iceland to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Icelandic Reportable Accounts on an automatic basis, pursuant to the provisions of Article 25 of the Convention Between the Government of the United States of America and the Government of Iceland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and accompanying Protocol (the “Convention”), done at Washington on October 23, 2007.

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • October 26th, 2015

On June 09, 2014, the Government of the United States of America and the Government of the Republic of South Africa signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic of South Africa to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and South African Reportable Accounts on an automatic basis, pursuant to the provisions of Article 26 of the Convention between the United States of America and the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, done at Cape Town on February 17, 1997 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • November 9th, 2015

On August 8, 2014, the Government of the United States of America and the Government of Sweden signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of Sweden to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Swedish Reportable Accounts on an automatic basis, pursuant to the provisions of Article 26 of the Convention Between the Government of the United States of America and the Government of Sweden for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income done at Stockholm on September 1, 1994, together with a related exchange of notes, and as amended by the Protocol done at Washington on September 30, 2005 (together the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • April 19th, 2016

On July 13, 2015, the Government of the United States of America and the Government of the Republic of the Philippines signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic of the Philippines to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Philippine Reportable Accounts on an automatic basis, pursuant to the provisions of Article 26 of the Convention between the Government of the United States of America and the Government of the Republic of the Philippines with Respect to Taxes on Income, done at Manila on October 1, 1976 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • September 30th, 2015

On July 9, 2015, the Government of the United States of America and the Government of the Republic of India signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic of India to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Indian Reportable Accounts on an automatic basis, pursuant to the provisions of Article 28 of the Convention between the Government of the United States of America and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, together with a related protocol (“Convention”), done at New Delhi on September 12, 1989.

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • November 3rd, 2015

On May 31, 2013, the United States of America and the Federal Republic of Germany signed an intergovernmental agreement (“IGA”) entitled, “Agreement Between the United States of America and the Federal Republic of Germany to Improve International Tax Compliance and with respect to the United States Information and Reporting Provisions Commonly Known as the Foreign Account Tax Compliance Act”. The IGA requires, in particular, the exchange of certain information with respect to U.S. and German Reportable Accounts on an automatic basis, pursuant to the provisions of Article 26 of the Convention between the United States of America and the Federal Republic of Germany for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital and to Certain Other Taxes, signed at Bonn on August 29, 1989, as amended by the Protocol signed at Berlin on June 1, 2006 (the “Convention”).

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COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • March 29th, 2016

On June 30, 2014, the Government of the United States of America and the Government of Israel signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the State of Israel to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Israeli Reportable Accounts on an automatic basis, pursuant to the provisions of Article 29 of the Convention between the Government of the United States of America and the Government of the State of Israel with Respect to Taxes on Income, done at Washington on November 20, 1975, as amended (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • November 12th, 2015

On June 27, 2014, the Government of the United States of America and the Government of Republic of Latvia signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic Of Latvia to Improve International Tax Compliance and to Implement FATCA”. The IGA requires, in particular, the exchange of certain information with respect to U.S. and Latvian Reportable Accounts on an automatic basis, pursuant to the provisions of Article 27 of the Convention between the United States of America and the Republic of Latvia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, done at Washington on January 15, 1998 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • September 15th, 2023

On April 15, 2013, the Government of the United States of America and the Government of the Kingdom of Norway signed an intergovernmental agreement (“IGA”) entitled, “Agreement Between the Government of the United States of America and the Government of the Kingdom of Norway to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Norwegian Reportable Accounts on an automatic basis, pursuant to the provisions of Article 28 of the Convention between the Government of the United States of America and the Government of the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Property (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • January 6th, 2016

On July 29, 2015, the Government of the United States of America and the Government of the Republic of Turkey signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic of Turkey to Improve International Tax Compliance through Enhanced Exchange of Information.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Turkish Reportable Accounts on an automatic basis, pursuant to the provisions of Article 26 of the Agreement Between the Government of the United States of America and the Government of the Republic of Turkey for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, together with a Related Protocol, signed at Washington on March 28, 1996 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • November 18th, 2015

On November 19, 2012, the Government of the United States of America and the Government of the Kingdom of Denmark signed an intergovernmental agreement

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • January 30th, 2020

On May 13, 2019, the Government of the United States of America and the Government of the Republic of Tunisia signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic of Tunisia to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and the Republic of Tunisia Reportable Accounts on an automatic basis, pursuant to the provisions of Article 26 of the Convention between the Government of the United States of America and the Government of the Tunisian Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed at Washington on June 17, 1985, as amended by the Supplementary Protocol, signed at Tunis on October 4, 1989 (together the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • March 7th, 2017

On November 3, 2014, the Government of the Commonwealth of The Bahamas and the Government of the United States of America signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the Commonwealth of The Bahamas and the Government of the United States of America to Implement

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • October 22nd, 2019

On May 16, 2014, the Government of the United States of America and the Government of the Principality of Liechtenstein signed an intergovernmental agreement ("IGA") entitled, "Agreement between the Government of the United States of America and the Government of the Principality of Liechtenstein to Improve International Tax Compliance and to Implement FATCA." The IGA requires, in particular, the exchange of certain information with respect to U.S. and Liechtenstein Reportable Accounts on an automatic basis, pursuant to the provisions of the "Agreement between the Government of the United States of America and the Government of the Principality of Liechtenstein on Tax Cooperation and the Exchange of Information Relating to Taxes" (the "TIEA"), done at Vaduz on December 8, 2008 and a protocol amending the TIEA done at Vaduz on May 16, 2014 (the "Protocol").

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • April 20th, 2016

On November 14, 2013, the Government of the United States of America and the Government of The French Republic signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the French Republic to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and French Reportable Accounts on an automatic basis, pursuant to the provisions of Article 27 of the Convention between the Government of the French Republic and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, done at Paris on August 31, 1994, as amended by the Protocols, signed at Washington on December 8, 2004 and at Paris on January 13, 2009 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • September 11th, 2015

On August 4, 2014, the United States of America and the Czech Republic signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the United States of America and the Czech Republic to Improve International Tax Compliance and with respect to the United States Information and Reporting Provisions Commonly Known as the Foreign Account Tax Compliance Act.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Czech Reportable Accounts on an automatic basis, pursuant to the provisions of Article 27 of the Convention between the United States of America and the Czech Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income done at Prague on September 16, 1993 (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • November 17th, 2015

On December 13, 2013, the Government of the United States of America and the Government of the Isle of Man signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Isle of Man to Improve International Tax Compliance and to

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • October 30th, 2015

On May 28, 2015, the United States of America and Romania signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the United States of America and Romania to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. and Romanian Reportable Accounts on an automatic basis, pursuant to the provisions of Article 24 of the Convention between the Government of the United States of America and the Government of the Socialist Republic of Romania with Respect to Taxes on Income, done at Washington on December 4, 1973, at Washington (the “Convention”).

COMPETENT AUTHORITY ARRANGEMENT
Competent Authority Arrangement • March 3rd, 2016

On December 5, 2014, the Government of the United States of America and the Government of the Republic of Bulgaria signed an intergovernmental agreement (“IGA”) entitled, “Agreement between the Government of the United States of America and the Government of the Republic of Bulgaria to Improve International Tax Compliance and to Implement FATCA.” The IGA requires, in particular, the exchange of certain information with respect to U.S. Reportable Accounts on an automatic basis, pursuant to the provisions of Article 25 of the Convention between the Government of the United States of America and the Government of the Republic of Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (the “Convention”), along with a Protocol, done at Washington on February 23, 2007.

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