Reservations and Declarations for Treaty No.127 - Convention on Mutual Administrative Assistance in Tax Matters

Nature of declaration : Reservations
Status as of 26/06/2019

El Salvador

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 26 February 2019 - Or. Engl., and supplemented by a Note verbale from the Embassy of El Salvador in France, dated 20 May 2019, registered at the Secretariat General of the OECD on 21 May 2019 – Or. Fr.

Pursuant to Article 30, paragraph 1.a, of the Convention, El Salvador reserves the right not to provide any form of assistance in relation to the taxes of other Parties included in any of the following categories listed in Article 2, paragraph 1.b:

i.: Taxes on income, profits, capital gains or net wealth which are imposed on behalf of political subdivisions or local authorities of a Party;

iii.A.: Estate, inheritance or gift taxes,
iii.F.: Taxes on the use or ownership of movable property other than motor vehicles,
iii.G.: Any other taxes;

iv.: Taxes in categories referred to in sub-paragraph iii above which are imposed on behalf of political subdivisions or local authorities of a Party.
Period covered: 01/06/2019 -
Articles concerned : 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 26 February 2019 - Or. Engl., and supplemented by a Note verbale from the Embassy of El Salvador in France, dated 20 May 2019, registered at the Secretariat General of the OECD on 21 May 2019 – Or. Fr.

Pursuant to Article 30, paragraph 1.b, of the Convention, El Salvador reserves the right not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes.
Period covered: 01/06/2019 -
Articles concerned : 30

Reservation contained in the instrument of ratification deposited with the Secretariat General of the OECD on 26 February 2019 - Or. Engl., and supplemented by a Note verbale from the Embassy of El Salvador in France, dated 20 May 2019, registered at the Secretariat General of the OECD on 21 May 2019 – Or. Fr.

Pursuant to Article 30, paragraph 1.f, of the Convention, El Salvador reserves the right to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.
Period covered: 01/06/2019 -
Articles concerned : 28, 30


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