Latin America DTTs, TIEAs and others (Through October 31, 2012) DTTs in force Being applied Argentina
4/ 5/
1/
16
TIEAs in force
TIEAs signed, but not in force
Agreements according to CIAT Model
Multilateral 2/ 3/ Agreements
12
2
4
1
2
6/
2
4
1
1
3
7/
2
3
8/
Pending application
DTTs signed, but not in force
1
2
Bolivia
7
Brazil
31
Chile
24
1
2
1
Colombia
4
1
5
1
1
Costa Rica
1
2
6
9
2
Dominican R.
1
1
1
Ecuador
12
2
1
El Salvador
1
1
Guatemala
7
Honduras Mexico
DTTs or TIEAs that are no longer in force
1
1
1 1
42
1
8
12
Panama
9
1
4
1
Paraguay
2
Peru
4
4
1
Nicaragua
1
Uruguay
6
Venezuela
31
1
6
1
1 9
1
9/
1
10/
1
Source: CIAT, IBFD and Tax Authorities. 1/ In the case of Bolivia, Colombia, Ecuador and Peru includes Decision 578 of the Andean Community (2004), which is based on the source principle. It replaced Decision 40 of the Cartagena Agreement which created the Common System for Avoiding Double Taxation (1972). Ratification may be pending in some countries. 2/ In the case of Costa Rica, El Salvador, Guatemala, Honduras and Nicaragua includes the Multilateral Agreement on Mutual Assistance and Technical Cooperation between the Tax and Customs Administrations of Central America (2006). Ratification may be pending in some countries. 3/ In the case of Argentina, Brazil, Colombia, Costa Rica and Mexico includes the Global Forum’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Ratification may be pending in some countries. 4/ The DTTs signed with Bolivia and Chile are based on the Andean Community model, which is based on the source principle. 5/ The Federal Administration of Public Income – (AFIP), Argentina and the Guardia di Finanza of the Italian Republic have signed in 2010 a Memorandum of Understanding on Cooperation and Information Exchange. This legal document came into effect from the date thereof. 6/ Both were DTTs. One with Austria (in force from 01/17/1982 to 01/01/2009), and the other with Sweden (in force from 12/14/1962 to 01/01/1998). The last one was replaced with another which came into force on 01/01/1998, the same completion day of the previous DTT signed between both countries. 7/ The 3 were DTTs. Germany (in force from 12/30/1975 to 01/01/2006), Finland (in force from 12/22/1973 to 01/01/1998), and Portugal (in force from 09/10/1971 to 01/01/2000). 8/ One DTT with Germany (in force from 12/30/1993 to 01/01/2010) replaced with another which came into force from 01/01/2010, the same completion 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. México also signed a TIEA with Canada (in force from 04/27/1992 to 01/01/2008). 9/ The DTT with Sweden (in force from 06/18/1968 to 01/01/2007). 10/ The DTT with Germany, (in force from 06/28/1990 to 01/01/2012) was replaced with another which became effective on 01/01/2012, the same completion day of the previous one.