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CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Regulation shall apply to taxes on income, inheritance taxes, registration fees, other than the inheritance taxes, stamp duties imposed on behalf of each Member State, its political subdivisions and its local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on wages or salaries paid as well as taxes on capital appreciation. There shall be regarded as estate taxes any taxes levied upon death of a person in the form of taxes on the estate, taxes on parts of an estate, capital transfer tax or taxes on gifts mortis causa.

There shall be considered as registration fees and stamp duties, taxes, duties or fees levied on civil, judicial or extrajudicial acts/deeds, presented or submitted to the formality of registration or stamp duty.

(3) The existing taxes to which the Regulations applies in each of the Member States are listed in the Annexure to this Regulation, of which it is an integral part.

(4) This Regulation shall apply also to any identical or substantially similar taxes that would be established after its date of entry into force, in addition to or in place of the existing taxes.

The competent authorities of the Member States shall notify each other, at the end of each year, of the significant changes made in their respective taxation laws or other laws affecting their obligations under this Regulation.

They shall inform the Commission about it, which shall take, if necessary, appropriate measures brought about by these changes.