The member states of the Council of Europe and the countries and members of the Organisation for Economic Co-operation and Development, signing this Agreement.

Whereas the development of the international movement of persons, capital, goods, and services - despite the significant benefits derived from it - has led to an increased likelihood of cases of tax avoidance and evasion, necessitating the enhancement of cooperation among tax authorities.

Welcoming the various efforts made in recent years to combat tax avoidance and evasion at the international level, whether bilaterally or multilaterally.

Recognizing the necessity of coordinating efforts among countries to improve all forms of administrative assistance in tax-related matters of any kind while ensuring adequate protection of taxpayers' rights.

Acknowledging the importance of international cooperation in facilitating the accurate determination of tax liabilities and assisting taxpayers in protecting their rights.

Recognizing that the fundamental principles granting every person the right to have their rights and obligations determined according to a proper legal procedure apply to tax matters in all countries, and that states should strive to protect the legitimate interests of taxpayers, including adequate protection against discrimination and double taxation.

Therefore, being convinced that states should implement procedures or provide information while ensuring the confidentiality of information, taking into account international tools for privacy protection and the flow of personal data.

Considering the emergence of a new cooperation environment and the need to provide a multilateral instrument that allows the maximum number of countries to benefit from its advantages according to the highest standards of international cooperation in the field of taxes.

Desiring to conclude an Agreement on mutual administrative assistance in tax matters, have agreed as follows:

1. Subject to the provisions in Chapter Four, the parties shall provide administrative assistance to each other in tax matters, which may include, when appropriate, procedures undertaken by judicial authorities.

2. Such administrative assistance consists of:

• A- Exchange of information including simultaneous tax audits and participation in audits abroad,

• B- Assistance in collection, including enforcement procedures, and

• ت- Service of documents.

3. The party provides administrative assistance whether the person concerned is a resident or citizen of the party's country or any other country.

1. The Agreement applies to:

• A- The following taxes:

  • 1- Taxes on income or profits,

  • 2- Taxes on capital gains which are imposed independently of taxes on income or profits,

  • 3- Taxes on net wealth imposed on behalf of a Party, and

• B- The following taxes:

  • 1- Taxes on income, profits, capital gains, or net wealth imposed on behalf of political subdivisions or local authorities of the Party,

  • 2- Mandatory social security contributions due to the public government or to social security institutions established under public law, and

  • 3- Taxes of other categories, except for customs duties, imposed on behalf of a Party, specifically:

    • A- Taxes on real estate, inheritances, or gifts,

    • B- Taxes on immovable property,

    • C- General consumption taxes, such as value-added taxes or sales taxes,

    • D- Specific taxes on goods or services such as entertainment taxes,

    • E- Taxes on the use or ownership of vehicles,

    • F- Taxes on the use or ownership of movable property other than vehicles,

    • G- Any other taxes,

  • 4- Taxes of the categories referred to in subparagraph 3 above which are imposed on behalf of a political subdivision or local authority of the Party.

2. The current taxes to which the Agreement applies are listed in Appendix A in the categories referred to in paragraph 1.

3. The Parties shall notify the Secretary General of the Council of Europe or the Secretary General of the Organisation for Economic Co-operation and Development (referred to in this Agreement as the Parties with whom the Agreement is deposited) of any change made to Appendix A as a result of the amendment of the list mentioned in paragraph 2, such change shall take effect on the first day of the month following the expiration of a three-month period after the date of receipt by the depositary of such notice.

4. The Agreement also applies to any similar or substantially similar tax imposed after the entry into force of the Agreement in relation to that Party in addition to or in place of the current taxes listed in Appendix A, and in that case, the concerned Party shall notify one of the depositary entities of the imposition of the relevant taxes.

1. For the purposes of this Agreement, unless the context requires otherwise:

• A- The phrases "Requesting State" and "Requested State" mean, respectively, any Party that requests administrative assistance in tax matters and any Party required to provide such assistance.

• B- The term "Tax" means any tax or social security contribution to which the Agreement applies in accordance with Article (2).

• ت- The term "Tax Claim" means any amount of tax plus interest thereon, penalties, and administrative costs related to collection, that is due and has not yet been paid.

• ث- The term "Competent Authority" means the persons and authorities listed in Appurtenance B.

• C- The term "Citizens" with respect to a Party means:

  • 1- All individuals who hold the nationality of that Party, and

  • 2- All legal entities, partnerships, associations, and any entities deriving that status from the applicable laws of that Party.

• For each Party that has made a declaration for that purpose, the terms used above shall be understood as defined in Appurtenance C.

2. Regarding the application of this Agreement by any Party, any term not defined herein, unless the context requires otherwise, shall have the same meaning as provided in the laws of that Party concerning the taxes covered by the Agreement.

3. The Parties shall notify one of the Depository Authorities of any changes to Appurtenances B and C, and such change shall take effect on the first day of the month following the expiration of a three-month period after the date of receipt by the relevant Depository Authority of such Notice.

1.  The parties shall exchange any information, specifically as stated in this section, that is expected to be relevant for the administration or mandatory enforcement of their local tax systems covered by this Agreement.

2. Repealed.

3. Any party may, by a declaration addressed to one of the depositary entities, indicate that according to its local legislation, its competent authorities may inform the citizen or resident before sending information related to him, in accordance with Articles (5) and (7).

1. Based on the request of the requesting state, the requested state shall provide the requesting state with any information referred to in Article (4) related to specific persons or transactions.

2. If the information available in the tax files of the requested state is insufficient to enable it to fulfill the request for information, that state shall take all relevant procedures to provide the requested information to the requesting state.