dtc agreement between monaco and qatar

8/3/2019 DTC agreement between Monaco and Qatar

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AGREEMENT

BETWEEN

THE GOVERNMENTOF THE PRINCIPALITY OF MONACO

AND

THE GOVERNMENTOF THE STATE OF QATAR

FOR THE AVOIDANCE OF DOUBLE TAXATIONAND THE PREVENTIONOF FISCAL EVASIONWITH RESPECT TO TAXES ON INCOME

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case to the competent authority of the Contracting State of whichhe is a resident or, if his case comes under paragraph 1 of Article24, to that of the Contracting State of which he is a national. Thecase must be presented within two years from the first notificationof the action resulting in taxation not in accordance with theprovisions of the Agreement.

2. The competent authority shall endeavour, if the objection appearsto it to be justified and if it is not itself able to arrive at asatisfactory solution, to resolve the case by mutual agreement withthe competent authority of the other Contracting State, with a viewto the avoidance of taxation which is not in accordance with theAgreement.

3. The competent authorities of the Contracting States shallendeavour to resolve by mutual agreement any difficulties ordoubts arising as to the interpretation or application of theAgreement. They may also consult together for the elimination ofdouble taxation in cases not provided for in the Agreement.4. The competent authorities of the contracting States maycommunicate with each other directly, including through a joint

commission consisting of themselves or their representatives, forthe purpose of reaching an agreement in the sense of the precedingparagraphs.

ARTICLE 26EXCHANGE OF INFORMATION

1. The competent authorities of the Contracting States shall exchangesuch information as is relevant for carrying out the provisions ofthis Agreement or of the domestic laws of the Contracting Statesconcerning taxes covered by the Agreement insofar as the taxationthereunder is not contrary to this Agreement.

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2. Any information received under paragraph I by a ContractingState shall be treated as secret in the same manner as informationobtained under the domestic law of that State. However, if theinformation is originally regarded as secret in the transmittingState, it shall be disclosed only to persons or authorities (includingcourts and administrative bodies) concerned with the assessment orcollection of, the enforcement or prosecution in respect of, or thedetermination of appeals in relation to the taxes covered by theAgreement. Such persons or authorities shall use the informationonly for such purposes. They may disclose the information inpublic court proceedings or in judicial decisions.

3. In no case shall the provisions of paragraphs I and 2 be construedso as to impose on a Contracting State the obligation:(a) to carry out administrative measures at variance with thelaws or the administrative practice of that or of the otherContracting State;(b) to supply information which is not obtainable under thelaws or in the normal course of the administration of thator ofthe other Contracting State;(c) to supply information which would disclose any trade,business, industrial, commercial or professional secret ortrade process, or information, the disclosure of whichwould be contrary to public policy (ordre public).

4. If information is requested by a Contracting State in accordancewith this Article, the other Contracting State shall use itsinformation gathering measures to obtain the requestedinformation, even though that other State may not need suchinformation for its own tax purposes. The obligation contained inthe preceding sentence is subject to the limitations of paragraph 3but in no case shall such limitations be construed to permit aContracting State to decline to supply information solely becauseit has no domestic interest in such information.

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5. In no case shall the provisions of paragraph 3 be construed topennit a Contracting State to decline to supply the requestedinfonnation solely because the infonnation is held by a bank orother fmancial institution, nominee or person acting in an agencyor a fiduciary capacity or because it relates to ownership interestsin a person.

ARTICLE 27MEMBERS OF DIPLOMATIC MISSIONS

AND CONSULAR POSTS

Nothing in this Agreement shall affect the fiscal privileges ofmembers ofdiplomatic missions or consular posts under the general rules ofinternational law or under the provisions of special agreements.

ARTICLE 28ENTRY INTO FORCE

1. The Contracting States shall notify each other in writing, throughdiplomatic charmels, of the completion of the procedures requiredby their laws for the bringing into force of this Agreement. TheAgreement shall enter into force on the thirtieth day from the dateof the later of these notifications.

2. The provisions of this Agreement shall have effect:(a) with regard to taxes withheld at source, in respect ofamounts paid or credited on or after the first day of Januaryof the calendar year immediately following the year inwhich the Agreement enters into force; and

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IN WITNESS WHEREOF the undersigned, being duly authorizedthereto, have signed this Agreement.

Done in duplicate at Doha the September 16 th day of2009, in the Arabic,French and English languages, all texts being equally authentic. In caseof any divergence, the English text shall prevail.

For the Governmentof the Principality ofMonaco:

dtc agreement between monaco and qatar

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