Title: WORKING ARRANGEMENT BETWEEN THE MINISTRY OF FINANCE OF THE ITALIAN REPUBLIC AND THE MINISTRY OF FINANCE OF THE SLOVAK REPUBLIC
Author: UCRI
Last saved by: utente
Company: Ministero delle Finanze

WORKING ARRANGEMENT BETWEEN THE MINISTRY OF FINANCE OF THE ITALIAN REPUBLIC AND THE MINISTRY OF FINANCE OF THE SLOVAK REPUBLIC UNDER  THE TERMS OF THE EXCHANGE OF INFORMATION PROVISIONS OF THE CONVENTION  BETWEEN ITALY AND CZECHOSLOVAKIA FOR  THE  AVOIDANCE  OF  DOUBLE  TAXATION  WITH RESPECT TO TAXES ON INCOME AND  THE PREVENTION OF FISCAL EVASION,SIGNED AT PRAGUE ON 5TH MAY 1981

The Convention between Italy and Czechoslovakia for the avoidance of double taxation with respect to taxes on income and  for the prevention of fiscal evasion, signed on 5th May, 1981, provides  in its Article 26 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 insofar as the taxation thereunder  is in accordance with this  Convention, as  well  as  for  the  prevention  of tax avoidance and fiscal evasion.  The exchange of information is not restricted by Article 1".

In order to achieve more efficiency in the exchange of information 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  Country  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 Country - 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 provision  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 Slovak Republic which is a spontaneous exchange of information  shall be routed between the persons designated as Competent Authorities by the Italian Republic and the Slovak Republic as applicable;

e)	it  is  mutually  understood  that information  provided  as spontaneous exchange  is  restricted  as  to its  use  within  the provisions and the terms of  article 26 of said Tax Convention between Italy and Czechoslovakia.  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 treaty and  that  its  use  and disclosure  are  governed  by  the provisions of the Convention;

f)	this arrangement shall be operative starting from January 1st, 1998;

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

- as far as the Slovak Republic is concerned, the “Ministry of Finance of the Slovak Republic - Tax and Customs Section - International Tax Affairs Department”;

- 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 22th April, 1997, in the English language.

For the Ministry of Finance                                  For the Ministry of Finance
of the Italian Republic                                          of the Slovak Republic

(G.M.LONGO)                                                    (Eva SIMKOVÁ)