tpa_i

Page 1

DTTs being applied in Latin America Through October 31, 2012 Country Argentina 2/ 3/

Bolivia 1/

Brazil 4/

19611971-1980 1970

1981-1990

1991

1992

1993

1994

Brazil Germany Chile Bolivia Italy France Argentina Austria Belgium Denmark Japan Spain France Sweden

Chile

1995

1996

Canada Spain

Argentina Canada Hungary Ecuador Czech Rep. Italy Slovak Rep. Luxembourg Norway

Finland Sweden United Kingdom

Germany

Korea (Rep.) Philippines India The Netherlands

1997

1998 Denmark United Kingdom Sweden

France

China (People's Rep.)

1999 The Netherlands

2000

2001

Australia Belgium

2002

Argentina

2006

2007

2008

2009

2010

2011

2012

TOTAL 16

Portugal

Chile

Canada Mexico

Brazil Korea (Rep.) Ecuador Spain Norway Peru Poland

7

Israel

Croatia Denmark United Kingdom

Sweden

Mexico South Africa Ukraine

Peru Russia

Venezuela

31

Ireland Belgium Malasia Colombia Switzerland Paraguay Thailand Portugal

France New Zealand

Andean Community

Costa Rica

Ecuador 1/

2005

Andean Community

Colombia 1/ Dominican R.

2004

Norway

Spain

Finland

2003

Spain

Chile

24

Switzerland Spain

4 1

Canada

1 Germany Brazil Italy

France

Spain

Switzerland

Romania

Mexico

Canada

Chile Andean Community

Belgium

12

El Salvador

Spain

1

Guatemala Honduras Mexico 5/

France Sweden

USA United Kingdom

Spain Korea (Rep.) Japan The Netherlands Italy Norway Switzerland Singapore

Belgium Denmark

Finland Ireland

Chile Israel

Ecuador

Luxembourg Polonia Portugal Australia Czech Rep. Romania

Indonesia

Brazil Austria China Canada Greece (People's Rep.) Slovak Rep. New Zealand

Iceland Russia

India Germany Panama Barbados Uruguay South Africa

Hungary

42

Barbados Luxembourg Qatar Singapore Portugal

9

Nicaragua Korea (Rep.) Spain Mexico The Netherlands

Panama

Paraguay

Chile Canada Chile Andean Community

Peru 1/ 6/

Uruguay 7/

Venezuela

Taiwan

2

Brazil

4

Hungary

France Italy

Germany United Kingdom

The Netherlands Czech Rep. Switzerland Trinidad and Tobago

Belgium Norway Portugal Sweden

USA

Barbados Denmark Indonesia

Canada China Cuba (People's Rep.) Spain

1/ For Bolivia, Colombia, Ecuador and Peru, CAN Decision 578 (2004) is relevant, based on the income source location principle. This replaced Decision 40 of the Cartagena Agreement which created the Common Regime for Double Taxation Avoidance (1972). Ratification in some of these countries may be still pending. 2/ The DTTs signed with Bolivia and Chile follow the Andean Pact model, based on the income source location principle. 3/ A DTT was signed with Austria, which was in force from 01/17/1982 to 01/01/2009, and another with Sweden (in force from 12/14/1962 to 01/01/1998). The last one was replaced by another one which came into force on 01/01/1998, the ending day of the previous DTC signed between both countries. 4/ 3 signed DTTs have been expired. One was with Germany (in force from 12/30/1975 to 01/01/ 2006), another with Finland (in force from 12/22/1973 to 01/01/1998), and one with Portugal (in force from 05/11/1971 to 01/01/2000). 5/ A DTT with Germany was signed (in force from 12/30/1993 to 01/01/2010), replaced by another came into force from 01/ 01/2010, the ending day of the previous one, and another with Canada (in force from 05/11/1992 to 01/01/2008), which was also replaced with one that came into force on 01/01/2008. 6/ A DTT was signed with Sweden (in force from 12/14/1962 to 01/01/1998), replaced by another which came into force on 01/01/1998, the ending day of the previous one. 7/ A DTT with Germany was signed (in force from 06/28/1990 to 01/01/2012), replaced by a DTT that came into force on 01/01/2012, on the ending day of the previous one.

Kuwait

Austria Korea (Rep.) Iran Qatar

Belarus Malaysia Russia Vietnam

Mexico

Germany Spain Switzerland Portugal

6

Brazil

United Arab Emirates

31


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