One of the primary purposes of a tax treaty is to reduce or eliminate double taxation on income from sources within one of the countries paid to a resident of the other country that is a party to the treaty.  The Mutual Agreement Procedure (“MAP”) article of U.S. income tax treaties is designed to facilitate the “competent authority” process.  Competent authority process refers to all steps in the process of initiating and resolving a competent authority case.  

A Competent Authority Arrangement is a bilateral agreement between the United States and the treaty partner to clarify or interpret treaty provisions. Competent Authority Arrangements also exist between the United States Internal Revenue Service and each United States Territory and Commonwealth tax agency to address issues of interest to the respective jurisdictions.

Note that every U.S. income tax treaty is different. Almost all U.S. income tax treaties have a MAP article, but the specific provisions of individual MAP articles will vary with each treaty.

Conceptually, the competent authority process can be separated into two phases, which roughly correspond to paragraphs 1 and 2 of the MAP article in most U.S. income tax treaties. Paragraph 1 covers the process of requesting competent authority assistance, while paragraph 2 covers the process to reach a competent authority resolution of such request. The process to reach a resolution under paragraph 2 may itself have two phases, the unilateral and bilateral phases.

Who Can Request Competent Authority Assistance?

Under most U.S. income tax treaties, a taxpayer must be a resident for treaty purposes (“treaty resident”), a national (as defined in the treaty), or a citizen of one of the Contracting States to the treaty to request competent authority assistance under that treaty. E.g., see U.S.- Canada Income Tax Treaty, Art. XXVI(1).  

Notes that  a person’s status as a “treaty resident” is separate from that person’s ! status as a resident under domestic tax law principles. A resident of a country for treaty purposes is a person who satisfies the requirements of the relevant treaty’s Resident article. E.g., see U.S. Model Treaty (2006), Art. 4.

From Whom Can a Taxpayer Request Competent Authority Assistance?

Under most U.S. income tax treaties, a taxpayer may request assistance from the competent authority of the country of which it is a treaty resident, national, or citizen. E.g., see U.S.­ Canada Income Tax Treaty, Art. XXVI(1). The U.S. Model Treaty (2006) and some U.S. income tax treaties allow for a taxpayer to request assistance from the competent authority of either Contracting State.

For What Can a Taxpayer Request Competent Authority Assistance?

A taxpayer can request competent authority assistance for any action of either Contracting State (i.e., U.S.-initiated action or foreign-initiated action) that results or will likely result in taxation not in accordance with the treaty. “Foreign-initiated action” and “U.S.-initiated action” refer to a foreign- or U.S.-initiated adjustment, or another action by or on behalf of the tax authority of a treaty country or IRS (such as withholding), that gives rise to a competent authority issue or makes it likely that a competent authority issue will arise.

The issue(s) covered in a taxpayer’s competent authority request is referred to as a “competent authority issue(s).” A “competent authority issue” is an issue that can be resolved by the U.S. competent authority, typically under the MAP article of a U.S. income tax treaty. Typically, a competent authority issue will be an action of a Contracting State which results or is likely to result in taxation not in accordance with an income tax treaty.

What is the Effect of Closed U.S. Statute of Limitation?

Under most U.S. income tax treaties, the taxpayer may request, and the U.S. competent authority may accept a request for, competent authority assistance even if the U.S. statute of limitations for claiming a refund (or other applicable time limit under U.S. law or the law of the other Contracting State) is closed. E.g., see U.S. Model Treaty (2006), Art. 25(1)). These domestic law procedural limitations may only be waived if a competent authority request is accepted and a competent authority resolution is reached. As a result, a taxpayer may want to take protective measures to ensure treaty notification is timely met.

Note that a U.S. income tax treaty may not increase the tax burden beyond the burden determined under domestic law. As a result, competent authority resolutions cannot be used to override U.S. statutes of limitation to impose additional tax, unless the taxpayer expressly agrees to this. See, e.g., Technical Explanation (TE) to U.S. Model Treaty (2006), Art. 1(2). Also see, e.g., TE to the U.S. Model Treaty (2006), Art. 25(2).

How Does a Taxpayer Request Competent Authority Assistance?

Taxpayers who are eligible to request assistance from the U.S. competent authority must do so in accordance with the governing U.S. income tax treaty, Rev. Proc. 2015-40 (or any successor), and any other applicable U.S. guidance. Requests for some types of competent authority assistance may have special filing requirements.

Note that on must distinguish U.S. income tax treaties (U.S. agreements with foreign countries) from U.S. tax coordination agreements (U.S. agreements with U.S. Territories – i.e., American Samoa, Guam, the Commonwealth of the Northern Marianas Islands, the Commonwealth of Puerto Rico, and the U.S. Virgin Islands). For guidance on the competent authority process under U.S. tax coordination agreements, refer to Rev. Proc. 2006-23.

A taxpayer can request competent authority assistance when it considers that the actions of one or both of the Contracting States to a U.S. income tax treaty result or will likely result for the taxpayer in double taxation or other taxation not in accordance with the governing treaty. E.g., see U.S. Model Treaty (2006), Art. 25(1).

Taxpayers should request competent authority assistance promptly after a competent authority issue(s) arises or is likely to arise, as many U.S. income tax treaties require that a competent authority request be filed, or require notification to the competent authority that such request will be filed, within a certain time limit (referred to as a treaty notification period).

The Competent Authority Arrangements for purposes of Country-by-Country exchange can be found separately below:

Country Arrangement
Algeria Competent Authority Arrangement Between the Competent Authorities of the United States of America and the People’s Democratic Republic of Algeria (PDF)
Anguilla Competent Authority Arrangement Between the Competent Authorities of the United States of America and Government of Anguilla (PDF)
Antigua and Barbuda Competent Authority Arrangement between the Competent Authorities of the United States of America and the Government of Antigua and Barbuda (PDF)
Australia Competent Authority Arrangement Between the Competent Authorities of The United States of America and Australia (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Australia on the Exchange of Country-by-Country Reports (PDF)

Austria U.S. – Austria: Tax Treatment of Certain Scholarships. March 1, 2005 (PDF)

U.S. – Austria : Taxing Deferred Payments to U.S. Citizens Residing in Austria. August 27, 2003 (PDF)

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Austria on the Exchange of Country-by-Country Reports (PDF)

Bahamas COMPETENT AUTHORITY ARRANGEMENT BETWEEN THE COMPETENT AUTHORITIES OF THE UNITED STATES OF AMERICA AND THE COMMONWEALTH OF THE BAHAMAS
(PDF)
Bahrain Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of Bahrain (PDF)
Barbados Competent Authority Arrangement Between the Competent Authorities of the United States of America and Barbados (PDF)
Belgium Announcement Concerning Mutual Agreement Procedure Arbitration under the Recent Income Tax Treaty Between the United States and Belgium

Memorandum of Understanding Between the U.S. and Belgium-2009

Arbitration Board Guidelines-2009

US-Belgium Limitation on Benefits – Equivalent Beneficiary. October 15, 2009 (PDF)

US-Belgium Agreement identifying Pensions for Treaty benefits. April 9, 2010 (PDF)

US-Belgium Tax Treatment of Fellowships. July 14, 2010 (PDF)

U.S.-Belgium Agreement Regarding Taxes Imposed by Belgian Municipalities – May 2011

Belgium Competent Authority Agreement – Profit Attribution – 7-16-13 (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of Belgium (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of Belgium on the Exchange of Country-By-Country Reports (PDF)

Bermuda Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Bermuda on the Exchange of Country-by-Country Reports (PDF)
Brazil Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Federative Republic of Brazil on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Government of the Federative Republic of Brazil (PDF)

British Virgin Islands Competent Authority Arrangement between the Competent Authorities of the United States of America and the Government of the British Virgin Islands (PDF)
Bulgaria Competent Authority Arrangement between the Competent Authorities of the United States of America and Republic of Bulgaria (PDF)
Cambodia Competent Authority Arrangement Between the Competent Authorities of The United States of America and the Royal Government of Cambodia (PDF)
Canada Memorandum of Understanding Between the Competent Authorities of Canada and The United States of America (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Canada on the Exchange of Country-By-Country Reports (PDF)

Arbitration Board Operating Guidelines (PDF)

Cayman Islands Competent Authority Arrangement Between the Competent Authorities of the Cayman Islands and the United States of America (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent  Authority of the Cayman Islands on the Exchange of Country-by-Country Reports (PDF)

China US – China MAP agreement Treaty Article 19-Professors and Teachers. November 24, 2010 (PDF)
Colombia Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Colombia (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Colombia on the Exchange of Country-by- Country Reports (PDF)

Costa Rica Competent Authority Arrangement between the Competent Authorities of the United States of America and Republic of Costa Rica (PDF)
Croatia Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Croatia (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Croatia on the Exchange of Country-By-Country Reports (PDF)

Curacao Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of the Netherlands, in Respect of Curacao (PDF)
Cyprus Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Cyprus (PDF)
Czech Republic Competent Authority Arrangement between the Competent Authorities of the United States of America and the Czech Republic (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Czech Republic on the Exchange of Country-By-Country Reports (PDF)

Denmark Competent Authority Arrangement Between the Competent Authorities of the United States of America and Kingdom of Denmark (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of Denmark on the Exchange of Country‐By‐Country Reports (PDF)

Dominica Competent Authority Arrangement Between the Competent Authorities of the United States of America and The Commonwealth of Dominica (PDF)
Dominican Republic Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Dominican Republic (PDF)
Estonia, Republic of Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Estonia (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Estonia on the Exchange of Country-By Country Reports (PDF)

Finland Competent Authority Arrangement Between the Competent Authorities of the United States of America and Republic of Finland (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Finland on the Exchange of Country-By-Country Reports (PDF)

France Competent Authority Arrangement Between the Competent Authorities of the United States of America and the French Republic (PDF)
Georgia Competent Authority Arrangement Between the Competent Authorities of the United States of American and Georgia (PDF)
Germany Arbitration Board Operating Guidelines

Memorandum of Understanding between the U.S. and Germany

US-Germany Agreement on Pensions – signed March 19, 2012

U.S. – Germany Mutual Agreement Regarding Taxation of Certain Consular Employees October 1, 2009 (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Germany (PDF)

Gibraltar Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Gibraltar on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Gibraltar (PDF)

Greece Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Hellenic Republic on the Exchange of Country-By-Country Reports (PDF)

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Hellenic Republic (PDF)

Greenland Competent Authority Arrangement Between the Competent Authorities of the United States of America and Greenland (PDF)
Grenada Competent Authority Arrangement Between the Competent Authorities of the United States of America and Grenada (PDF)
Guernsey Competent Authority Arrangement Between the Competent Authorities of the United States of America and the States of Guernsey (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Guernsey on the Exchange of Country‐By‐Country Reports (PDF)

Guyana Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Government of the Co-Operative Republic of Guyana to Improve International Tax Compliance and to Implement FATCA  (PDF)
Holy See Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Holy See, Acting Also in the Name and on Behalf of the Vatican City State 
(PDF)
Honduras Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Honduras (PDF)
Hungary Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Hungary on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Hungary (PDF)

Iceland Competent Authority Arrangement between the Competent Authorities of the United States of America and Iceland (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Iceland on the Exchange of Country-By Country Reports (PDF)

India U.S. – India: Memorandum Of Understanding Regarding Deferment Of Assessment And/Or Suspension Of Collection Of Taxes During Mutual Agreement Procedure. September 25, 2002 (PDF)

Competent Authority Arrangement Between the Competent Authorities of The United States of America and The Republic of India (PDF)

Indonesia Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Indonesia on the Exchange of Country-by-Country Reports (PDF)
Ireland Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Ireland on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement between the Competent Authorities of the United States of America and Ireland (PDF)

U.S. – Ireland: Competent Authority Agreement regarding the income received by Irish unit holders in a Common Contractual Fund – February 9, 2006

Agreement Between the Competent Authority of the United States of America and the Competent Authority of Ireland to Update Annex II of the Agreement Between the Government of the United States of America and the Government of Ireland to Improve International Tax Compliance and to Implement FATCA

Isle of Man Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Isle of Man on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Isle of Man (PDF)

Israel Competent Authority Arrangement Between the Competent Authorities of the United States of America and Israel (PDF)
Italy Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Italy (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Italy on the Exchange of Country-by-Country Reports (PDF)

Jamaica Arrangement between the Competent Authority of the United States of America and the Competent Authority of Jamaica on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Jamaica (PDF)

Japan Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Japan on the Exchange of Country-by-Country Reports (PDF)

U.S. – Japan: Guidance regarding the Commencement of Application of the new Tax Convention between the United States and Japan. June 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. December 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)

Jersey Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Jersey on the Exchange of Country-By Country Reports (PDF)
Korea, Republic of Arrangement between the Competent Authority of the United States of America and the Competent Authority of the Republic of Korea on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement Regarding the Interpretation of Article 3 (Fiscal Domicile) of the Income Tax Convention between the United States and Korea (PDF)

Kosovo Competent Authority Arrangement Between the Competent Authorities of The United States of America and the  Republic of Kosovo (PDF)
Kuwait Competent Authority Arrangement Between the Competent Authorities of The United States of America and the  State of Kuwait (PDF)
Latvia Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Latvia (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Latvia on the Exchange of Country-By-Country Reports (PDF)

Liechtenstein Competent Authority Arrangement between the Competent Authorities of the United States of America and the Principality of Liechtenstein (PDF)

Competent Authority Arrangement between the Competent Authorities of the United States of America and the  Principality of Liechtenstein on the Exchange of Country-by-Country Reports (PDF)

Lithuania Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Lithuania on the Exchange of Country-by-Country Reports (PDF)
Luxembourg U.S. – Luxembourg: Interpretation of Tax Treaty’s Transition Rules. November 09, 2001 (PDF)

Competent Authority Arrangement between the Competent Authorities of  the United States of America and the Grand Duchy of Luxembourg (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Grand Duchy of Luxembourg on the Exchange of Country-By-Country Reports (PDF)

Malta Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Malta on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement between the Competent Authorities of  the United States of America and Republic of Malta (PDF)

Mauritius Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Mauritius (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the United Mexican States on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Mauritius on the Exchange of Country-by-Country Reports (PDF)

Mexico U.S. – Mexico: Mutual Agreement Regarding Eligibility of Fiscally Transparent Entities to Benefits. August 26, 2005 (PDF)

U.S. – Mexico: Mutual Agreement Regarding Eligibility of Fiscally Transparent Entities to Benefits. December 22, 2005 (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the United Mexican States on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement Between the Competent Authorities of the Department of the Treasury of the United States of America and the Ministry of Finance and Public Credit of the United Mexican States (PDF)

Montserrat Competent Authority Arrangement between the Competent Authorities of the United States of America and Montserrat (PDF)
Netherlands U.S. – Netherlands Agreement Regarding Dutch Limited Funds for Mutual Account – May 21, 2012 (PDF)

U.S. – Netherlands: Updated Agreement Identifying Pensions for Treaty Benefits August 13, 2007 (PDF)

U.S. – Netherlands: Administrative Arrangements for Mutual Agreement Procedure. October 7, 2003 (PDF)

U.S. – Netherlands: Pensions Investing Through Hybrid entities. March 21, 2003 (PDF)

U.S. – Netherlands – Pensions Agreement modified to eliminate Dutch “Qualification” Certification. March 30, 2010 (PDF)

Competent Authority Arrangement between the Competent Authorities of the United States and Netherlands (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of the Netherlands on the Exchange of Country-By-Country Reports (PDF)

New Zealand U.S. – New Zealand: Mutual Agreement Regarding Treatment of Income Derived Through Certain Fiscally Transparent Entities. February 10, 2005 (PDF)

Competent Authority Arrangement between the Competent Authorities of the United States of America and New Zealand (PDF)

U.S. – New Zealand Competent Authority Arrangement Regarding Meaning of the Term “Resident in New Zealand” under the IGA for a Financial Institution that is a Trust (other than a Unit Trust) (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of New Zealand on the Exchange of Country‐By‐Country Reports (PDF)

Norway U.S. – Norway – Agreement Regarding Offshore Activities – February 2013 (PDF)

U.S. – Norway – Eligibility of Fiscally Transparent Entities for Treaty Benefits – January 2013 (PDF)

U.S. – Norway – Source of Remuneration for Government Services and Social Security Payments – December 2012 (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of Norway 

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of Norway on the Exchange of Country-By-Country Reports (PDF)

Panama Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Panama (PDF)
Philippines Competent Authority Arrangement Between the Competent Authorities of The United States of America and the Republic of the Philippines (PDF)
Poland Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Poland on the Exchange of Country-by-Country Reports (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Poland (PDF)

Portugal Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Portuguese Republic on the Exchange of Country-By-Country Reports (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and Portugal (PDF)

Qatar Competent Authority Arrangement Between the Competent Authorities of the United States of America and the  State of Qatar (PDF)
Romania Competent Authority Arrangement Between the Competent Authorities of the United States of America and Romania (PDF)
Saint Kitts and Nevis Competent Authority Arrangement between the Competent Authorities of the United States of America and the Federation of St. Kitts and Nevis (PDF)
Saint Lucia Competent Authority Arrangement Between the Competent Authorities of the United States of America and Saint Lucia (PDF)
Saudi Arabia Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of Saudi Arabia (PDF)
Slovak Republic Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Slovak Republic (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Slovak Republic on the Exchange of Country-By-Country Reports (PDF)

Slovenia Competent Authority Arrangement between the Competent Authorities of the United States of America and the Republic of Slovenia (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of Slovenia on the Exchange of Country-by-Country Reports (PDF)

South Africa Competent Authority Arrangement between the Competent Authorities of  the United States of America and the Republic of South Africa (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Republic of South Africa on the Exchange of Country-by-Country Reports (PDF)

Spain U.S.- Spain Agreement Regarding Eligibility of Benefits to Fiscally Transparent Entities. February 15, 2006 (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Kingdom of Spain (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the Kingdom of Spain on the Exchange of Country-By-Country Reports (PDF)

St. Vincent and the Grenadines Competent Authority Arrangement Between the Competent Authorities of the United States of America and St. Vincent and the Grenadines (PDF)
Sweden Competent Authority Arrangement Between the Competent Authorities of the United States of America and Sweden (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of Sweden on the Exchange of Country-By-Country Reports (PDF)

Switzerland U.S.-Swiss: References to NAFTA upon entry into force of USMCA. June 25, 2020 (PDF)

U.S. – Swiss: Pension Plans for Tax Treaty Benefits. December 10, 2004 (PDF)

US – Swiss: Guidance on Treaty Benefits. August 22, 2003 (PDF)

Turkey Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Turkey (PDF)
Turks and Caicos Islands Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Turks and Caicos Islands (PDF)
United Arab Emirates Competent Authority Arrangement Between the Competent Authorities of the United States of America and the United Arab Emirates (PDF)
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. October 6, 2006 (PDF)

U.S. – U.K.: Agreement Identifies U.K. Pension Arrangements for Tax Treaty Benefits. April 13, 2005 (PDF)

U.S. – U.K.: New Administrative Arrangements for Mutual Agreement Procedure. November 13, 2000 (PDF)

Competent Authority Arrangement Between the Competent Authorities of the United States of America and United Kingdom of Great Britain and Northern Ireland (PDF)

Arrangement Between the Competent Authority of the United States of America and the Competent Authority of the United Kingdom of Great Britain and Northern Ireland on the Exchange of Country-By-Country Reports (PDF)

Agreement Between the Competent Authority of the United States of America and the Competent Authority of the United Kingdom of Great Britain and Northern Ireland to update Annex II of the 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 Implement FATCA (PDF)

Uzbekistan Competent Authority Arrangement Between the Competent Authorities of the United States of America and Uzbekistan (PDF)
Vietnam Competent Authority Arrangement between the Competent Authorities of the United States of America and the Socialist Republic of VIET NAM (PDF)

 

Territory Arrangement
American Samoa Tax Implementation Agreement between the United States of America and American Samoa (PDF)
Guam Agreement on Coordination of Tax Administration – Department of Revenue and Taxation of Guam and the United States – Internal Revenue Service (PDF)
Northern Mariana Islands Tax Coordination Agreement between the United States of America and the Commonwealth of the Northern Mariana Islands (PDF)
Puerto Rico Tax Coordination Agreement between the United States of America and the Commonwealth of Puerto Rico (PDF)
U.S. Virgin Islands Tax Implementation Agreement between the United States of America and the Virgin Islands (PDF)