Title: WORKING ARRANGEMENT BETWEEN THE MINISTRY OF FINANCE OF THE ITALIAN REPUBLIC AND THE DIRECTORATE OF TAXES OF THE KINGDOM OF NOR
Author: Gfs
Last saved by: utente
Company: UCRI

WORKING ARRANGEMENT BETWEEN THE MINISTRY OF FINANCE OF THE ITALIAN REPUBLIC AND THE DIRECTORATE OF TAXES OF THE KINGDOM OF NORWAY UNDER THE TERMS OF THE EXCHANGE OF INFORMATION PROVISIONS OF THE CONVENTION BETWEEN ITALY AND NORWAY FOR THE AVOIDANCE OF DOUBLE TAXATION WITH  RESPECT TO TAXES ON INCOME AND ON CAPITAL AND THE PREVENTION OF FISCAL EVASION, SIGNED AT ROME ON  JUNE 17, 1985.

The Agreement between Italy and Norway for the avoidance of double taxation with respect to taxes on income and on capital and the prevention of fiscal evasion, signed on June 17, 1985, provides in its Article 27 that: "The competent authorities of the Contracting States shall exchange such information as is necessary for the carrying out of this Convention or of the domestic laws of the Contracting States concerning taxes covered by this Convention in so far as the taxation thereunder is not contrary to this Convention, as well as to prevent fiscal evasion. The exchange of information is not restricted by Article 1".

In order to achieve more efficiency in the exchange of information provided for by said Art. 27 and to reach the objective of the prevention of the evasion in the field of taxes provided for in that Convention the Competent Authorities of the two Contracting States have decided to proceed to a spontaneous exchange of information according to the following provisions:

a)	the Competent Authority of each Contracting State shall  supply, without any specific request, the Competent Authority of the other Contracting  State with information - acquired during examinations or controls of its taxpayers and concerning residents of that other Contracting State - which would be of interest for the correct assessment of taxes on income of said residents;

b)	such information shall include especially payments made, directly or indirectly, by a resident of one Contracting State to a resident of the other Contracting State consisting of rents for lease, interests, royalties, directors' fees, attendance fees, remuneration of artists and athletes, remuneration for independent personal services, commissions and  similar payments, and any other types of income;

c)	the two Competent Authorities also agree that reciprocity is an important aspect of the mutual co-operation and requires that the Competent Authorities continually maintain an atmosphere of freely exchanging information subject to the provisions of the Convention, in order to ensure that said exchange occurs appropriately and in accordance with principles of reciprocity;  

d)	any information exchanged between the Italian Republic and the Kingdom of Norway which is a spontaneous exchange of information  shall be routed between the persons designated as Competent Authorities by the Italian Republic and the Kingdom of Norway as applicable;

e)	it is mutually understood that the use of information provided as spontaneous exchange is restricted by the provisions and the terms of article 27 of said Convention between Italy and Norway. In order to prevent unauthorised disclosure, the Competent Authorities will specify on all information exchanged that information is provided subject to the terms of the Convention and that its use and disclosure are governed by the provisions of the Convention;

f)	this Arrangement shall be operative starting from the July 1, 1998;

g)	this Arrangement may be modified at any time by agreement between the Competent Authorities.
         
h)	For the purposes of this Arrangement the Competent Authorities are:

- as far as the Kingdom of Norway is concerned, the “Directorate of Taxes”;

- as far as the Italian Republic is concerned, the “Ministero delle Finanze - Segretariato Generale - Ufficio per gli Studi di Diritto Tributario Comparato e per le Relazioni Internazionali”.

	Done at Rome, in  duplicate, on April 8, 1998 in the English language.

For the Ministry of Finance         For the Directorate of Taxes
 of the Italian Republic               of the Kingdom of Norway

  (Michele del Giudice)                (Vidar St Johannessen)