Convention on Mutual Administrative Assistance in Tax Matters

Tax Advice & Tax Compliance

Convention on Mutual Administrative Assistance in Tax Matters


  • Convention on Mutual Administrative assistance in Tax Matters signed already by 146 countries
  • The agreement covers:
    1. Exchange of information
    2. Assistance in recovery of taxes
  • Service of documents
  • The agreement covers following taxes:
    1. Taxes on income or profits
    2. Taxes on capital gains
  • Taxes on net wealth
  • Information exchanged is information, which is foreseeably relevant for the administration or enforcement of their domestic laws concerning the taxes covered.
  • Information is exchanged under one of three methods:
    1. Exchange of Information upon request – (based on specific request made)
    2. Automatic exchange of information (on matters to be determined by mutual agreement of the two parties)
  • Spontaneous exchange of information (under certain conditions) 
  • Spontaneous exchange of information
    1. The first state may have grounds to believe that there would be losses of taxes in the other state.
    2. A person liable to tax gets exemption/reduction from taxes in one state which could result in increased taxes in the other state
  • Multiple jurisdictions are imposed between the two states which would result in savings in taxes
  1. Artificial transfers of profits between group companies

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