Liechtenstein Steps Up Signing Of TIEAs

by Ulrika Lomas, Tax-News.com, Brussels

28 September 2009

It has emerged that the principality of Liechtenstein has concluded a tax information agreement (TIEA) with France, and a double tax agreement (DTA) with San Marino, both of which are compliant with Organization of Economic Cooperation and Development (OECD) benchmarks.

The TIEA concluded with France follows the OECD Model Convention and provides for information exchange upon request applicable from the tax year 2010. The agreement applies to all taxes currently levied by the treaty parties. The agreement contains a non-discriminatory clause and will enter into force upon completion of the two countries' domestic ratification procedures.

Commenting on the new TIEA with France, Liechtenstein’s Deputy Prime Minister Martin Meyer stated that: "This agreement for the first time offers a framework and a procedure governed by the rule of law for cooperation between our two countries in tax matters. This is not only important for legal certainty, but is also a precondition for further strengthening our economic relations."

Liechtenstein and France have also agreed to continue negotiations on closer cooperation, and aim to conclude a double taxation agreement as soon as possible.

The bilateral DTA concluded between Liechtenstein and San Marino also conforms with the OECD’s Model Convention, and is also set to apply from the 2010 fiscal year.

In a determined bid to be removed from the OECD’s “grey list” of countries deemed uncooperative in international tax matters, Liechtenstein’s government aims to conclude at least 12 tax information exchange agreements by this autumn, and intends to advance negotiations on additional double taxation agreements thereafter.

San Marino, however, now appears on the OECD’s much-coveted “white list” of countries that have fulfilled the organisation’s official requirement to conclude 12 tax information exchange agreements, providing for administrative assistance in tax matters under Article 26 of the OECD Model Convention.

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