On November 4, 2015 the governments of the Isle of Man and Romania signed an Agreement for the Exchange of Information Relating to Tax Matters (TIEA). The TIEA arranges for the exchange of information upon request.

Although signed, the TIEA has not yet entered into force.

Below we will discuss a selection of provisions included in the TIEA of which we feel our readers might be interested in.

According to Article 3, Paragraph 1 of the TIEA (“Taxes Covered”), the TIEA shall apply to the following taxes imposed by the Parties: 

(a)    in the Isle of Man, taxes on income and taxes on profit; and

(b)    in Romania, the tax on income and the tax on profit.

Article 3, Paragraph 2 of the TIEA subsequently arranges that the TIEA shall also apply to any identical or substantially similar taxes imposed after the date of signature of the TIEA in addition to, or in place of, the existing taxes. Furthermore, the taxes covered may be expanded or modified by mutual agreement of the Parties in the form of an exchange of letters.

Article 5 of the TIEA contains regulations regarding the Exchange of Information upon Request.

Article 6 of the TIEA contains regulations regarding the Possibility of Declining a Request. Based on Paragraph 1 of Article 6 the competent authority of the requested Party may decline to assist where the request is not made in conformity with the TIEA.

Article 11 of the TIEA contains regulations regarding a Mutual Agreement Procedure. 

Click here to be forwarded to the text of the TIEA as available on the website of the Government of the Isle of Man, which will open in a new window.

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