The Government Of The Republic Of Latvia And The Gērns Of The National Agreement On Exchange Of Information For Tax Purposes

Original Language Title: Par Latvijas Republikas valdības un Gērnsi Valstu līgumu par informācijas apmaiņu attiecībā uz nodokļiem

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Read the untranslated law here: https://www.vestnesis.lv/op/2013/53.7


The Saeima has adopted and the President promulgated the following laws: For the Government of the Republic of Latvia and the Gērns of the national agreement for the exchange of information relating to taxes article 1. 2012 on September 5 in London signed by the Government of the Republic of Latvia and the Gērns of the national agreement on Exchange of information for tax purposes (hereinafter referred to as the Treaty) this law is adopted and approved.
2. article. Contractual commitments coordinated by the Ministry of finance.
3. article. The agreement shall enter into force for the period specified in article 12 and in order, and the Ministry of Foreign Affairs shall notify the official Edition of the "journal".
4. article. The law shall enter into force on the day following its promulgation. With the law put a contract in English and its translation into Latvian language. The Saeima adopted the law on 28 February 2013. The President of the Parliament instead of the President's Āboltiņ in Riga 15 March 2013 in the agreement BETWEEN the Government OF the REPUBLIC OF Latvia AND the States OF GUERNSEY FOR the Exchange OF INFORMATION RELATING TO TAX matters whereas the Government of the Republic of Latvia and the States of Guernsey have long been active in international efforts in the fight against financial crimes and others , including the targeting of the terrorist financing; Whereas it is acknowledged that the States of Guernsey has the right, under the terms of the Entrustmen from the United Kingdom of Great Britain and Northern Ireland, gotiat, it, perform and conclud subject to the terms of this Agreement terminate a tax information exchange agreement with the Government of the Republic of Latvia; Whereas the States of Guernsey on the 21st February 2002 entered into a political commitment to the OECD's principles of effective exchange of information; Whereas the parties wish to enhance and facilitat the terms and conditions of the exchange of information, each relating to taxes; NOW, therefore, the parties have agreed to conclud that following agreement which contains obligations on the part of the parties only: article 1 scope of the agreement of the competent authorities to be of the Parties shall provide assistance through exchange of information that is foreseeably relevant to the administration and enforcement of the domestic laws of the parties concerning the taxes covered by this agreement. Such information shall include information that is foreseeably relevant to the determination, assessment and collection of such taxes, the recovery and enforcement of tax claims, or the investigation of tax matters or prosecution of criminal tax matters. (A) the requested Party is not obliged to provide information which is not held by it for the ither authorities nor in the possession of, or obtainabl by a person who is within the territorial jurisdiction with it. The rights and safeguards secured to persons by the laws or administrative practice of the requested Party remain applicable to the exten to that they do not unduly prevent or delay effective exchange of information. Article 2 Taxes Covered 1. This agreement shall apply to the following taxes imposed by the parties: (a) in the case of Guernsey: (i) the income tax; (ii) the dwelling profits tax; (b) in the case of Latvia: (i) the enterprise income tax (income tax of enterprises); (ii) the micro-enterprise taxi (mikrouznemum tax); (iii) the personal income tax (will tax revenue); (iv) the immovabl property tax (tax on immovable property); (v) the value added tax (value added tax). 2. This agreement shall apply also to any identical taxes imposed after the date of signature of the agreement in addition to or in place of the existing taxes, or any substantially similar taxes if the parties so agree. Furthermore, the tax may be expanded or modified covered by mutual agreement of the parties in the form of an exchange of notes. The competent authority of each Party shall notify the other of substantial changes in laws which may affec the obligations of that Party to this agreement pursuan. Article 3 Definition of

1. In this agreement: (a) the "Guernsey" means the States of Guernsey, and when used in a location sense means Guernsey, Alderney and Herm, including the territorial sea adjacent to those islands, in accordanc with international law; (b) "Corporation" means the Republic of Latvia and, when used in the sense of location, means the territory of the Republic of Latvia and any other area adjacent to the territorial waters of the Republic of Latvia within which under the law of Latvia and, in accordanc with international law, the rights of Latvia may be exercised with respect to the sea bed and its sub soil and their-natural resources; (c) "collective investment fund or scheme" means any pooled investment vehicle, irrespectiv of legal form. The term "public collective investment fund or scheme" means any collective investment fund or scheme provided the units, shares or other interests in the fund or scheme can be readily purchased, sold or redeemed by the public. Units, shares or other interests in the fund or scheme can be readily purchased, sold or redeemed "by the public" if the purchase, sale or redemption is not implicitly or explicitly restricted to a limited group of investors; (d) "company" means any body corporate or any entity that is treated as a body corporate for tax purpose; (e) "competent authority" means: (i) in the case of Guernsey, the Director of income Tax or his delegate; (ii) in the case of Latvia, the State revenue service or its authorised representative except that, where a corporation is the requesting Party, the Prosecutor General or its authorised representative may act as the competent authority in respect of criminal tax matters; (f) "criminal laws" means all criminal laws designated as such under domestic law, such a irrespectiv of whethers led in the tax law, the criminal code or other statute; (g) "criminal tax matters" means tax matters involving intentional conduct whethers before or after the entry into force of this agreement which is liabl to prosecution under the criminal law of the requesting Party; (h) "information" means any fact, statement, document or record in whatever form; (i) "information gathering" measure "means laws and administrative or judicial procedures enabling a requested Party to obtain and provide the information requested; (j) "parties" means: (i) the Guernsey; and (ii) the Corporation; (k) "person" includes an individual, a company and any other body of persons; (l) "principal class of shares" means the class or classes of shares representing a majority of the voting power and value of the company; (m) "publicly traded company" means any company whose principal class of shares is listed on a recognised stock exchange provided its listed shares can be readily purchased or sold by the public. Shares can be purchased or sold "by the public" if the purchase or sale of shares is not implicitly or explicitly restricted to a limited group of investors; (n) "recognised stock exchange" means any stock exchange agreed upon by the competent authorities to be of the parties; (o) "requested Party" means the Party to this agreement which is requested to provide or has provided information or assistance in response to a request for information; (p) "requesting Party" means the Party to this agreement submitting a request for or having received information or assistance from the requested Party; (q) "tax" means any tax covered by this agreement. 2. As regards the application of this agreement at any time by a Party, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that Party, any meaning under the applicable tax laws of that Party prevailing over a meaning given to the term under other laws of that Party. Article 4 Exchange of Information Upon request

1. The competent authority of the requested Party shall provide upon request by the requesting Party for the purpose of the information referred to in article 1 shall be exchanged Such information without regards to whethers the requested Party needs such information for its own tax purpose or the conduct being investigated would constitut a crime under the law of the requested Party if it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information to pursuan this article when it is unable to obtain the requested information by other means within its own territory, except where recourses to such means would give rise to the disproportionat of difficulty. 2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, the requested Party shall at its own discretion use all relevant information gathering measure does not provide the cessary to requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purpose. 3. If specifically requested by the competent authority of the requesting Party, the competent authority of the requested Party shall provide information under this article, the allowabl of it is exten to under domestic law, in the form of deposition of witness and authenticated "cop out of original records. 4. Each Party shall ensur that its competent authorities, for the purpose of the specified in article 1 of the agreement, have the authority to obtain and provide upon request: (a) information held by banks, other financial institutions, and any person acting in an agency or fiduciary capacity including nominees and Trustees; (b) (i) information regarding the beneficial ownership of companies, partnerships, foundations, and others persons, including information on all such persons, ownership in an ownership chain; (ii) in the case of collective investment funds or schemes, information on shares, units and other interests; (iii) in the case of trusts, information on settlor, the Trustees, protectors, enforcer and beneficiar; (iv) in the case of foundations, information on founder, members of the foundation council and beneficiar. This agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment funds or schemes, unless such information can be obtained by without giving rise to the disproportionat is difficult. 5. Any request for information shall be formulated with the greatest detail possible and shall specify in writing: (a) the identity of the person under examination or investigation; (b) the period for which the information is requested; (c) the nature of the information requested and the form in which the requesting Party would prefer to receive it; (d) the tax purpose for which the information is sought; (e) the reason for believing that the information requested is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph; (f) the grounds for believing that the information requested is present or held in the requested Party or is in the possession of, under the control of or obtainabl by a person within the jurisdiction of the requested Party; (g) to the exten known, the name and address of any person believed to be in possession of, in the control of or able to obtain the information requested; (h) a statement that the request is in conformity with the law and administrative practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the law of the requesting Party or in the normal course of administrative practice and that it is in conformity with this agreement; (i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except where that would give rise to the disproportionat of difficulty. 6. The competent authority of the requested Party shall forward the requested information as promptly as possible to the requesting Party. To ensur a prompt response, the competent authority of the requested Party shall: (a) confirm receipt of a request in writing to the competent authority of the requesting Party and shall notify the competent authority of the requesting Party of deficienc to in the request, if any, within 60 days of the receipt of the request; (b) if the competent authority of the requested Party has been unable to obtain and provide the information within 90 days of receipt of the complete request, including if it encounters in the furnishings of the information removes the or it it furnish the information refus it shall immediately inform the competent authority of the requesting Party, explaining the reason for its inability, the nature of the removes the reason for or its refusal. Article 5 Tax Examination Abroad 1. At the request of the competent authority of the requesting Party, the competent authority of the requested Party may allow representatives of the competent authority of the requesting Party to enter its territory to interview individual and examin records with the prior written consent of the persons concerned. The competent authority of the requesting Party shall notify the competent authority of the requested Party of the time and place of the intended meeting. 2. At the request of the competent authority of the requesting Party, the competent authority of the requested Party may permit representatives of the competent authority of the requesting Party to attend a tax examination in the territory of the requested Party. 3. If the request referred to in paragraph 2 of this article is granted, the competent authority of the requested Party conducting the examination shall, as soon as possible, notify the competent authority of the requesting Party of the time and place of the examination, the authority or official designated to carry out the examination and the procedures and conditions required by the requested Party for the conduct of the examination. All Albert regarding the conduct of the examination shall be made by the requested Party conducting the examination. Article 6 Possibility of Declining a request

1. The competent authority of the requested Party may declin to assist: (a) where the request is not made in conformity with this agreement; (b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourses to such means would give rise to the disproportionat of difficulty; or (c) where the disclosure of the information requested would be contrary to public policy. 2. This agreement shall not impost upon a requested Party any obligation to provide items subject to legal privilege, or supply information which would disclos any trade, business, industrial, commercial or professional secret or trade process, provided that information described in article 4, paragraph 4, shall not by reason of that fact alone be treated as such a secret or trade process. 3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. 4. The requested Party shall not be required to obtain and provide information which, if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice. 5. The requested Party may request a declin for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which a national or the discriminat against a citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstanc. Article 7 Confidentiality 1 All information received by the competent authority of a Party shall be treated as confidential in the same manner as information obtained under the domestic law of that Party. 2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purpose specified in article 1 of, and used by such persons or authorities only for such purpose, including the determination of any appeal. For these purpose, information may be disclosed in public court proceedings or in judicial decisions. 3. Such information may not be used for any purpose other than for the purpose stated in the article 1 without the express written consent of the competent authority of the requested Party. 4. Information provided to a requesting Party under this agreement may not be disclosed to any other jurisdiction. Article 8 costs Unless the competent authorities to be of the parties otherwise agree, the indirect costs incurred in providing assistance shall be borne by the requested Party, and direct costs incurred in providing assistance (including costs of engaging external advisors in connection with litigation or otherwise) shall be borne by the requesting Party. The competent authorities shall be the respectiv consult from time to time with regards to this article, and in particular the competent authority of the requested Party shall consult with the competent authority of the requesting Party in advance if the costs of providing information with respect to a specific request are expected to be significant. Article 9 language requests for assistance and responses shall be drawn up of theret in English. Article 10 Mutual agreement procedures 1. difficult to doubt in the where clause or «arise between the parties regarding the implementation or interpretation of this agreement, the competent authorities shall be the respectiv use their best efforts to resolve the matter by mutual agreement. 2. In addition to the agreements referred to in paragraph 1 of this article, the competent authorities of the parties may mutually agree the on the procedures to be used under articles 4, 5 and 8. The parties may also agree on other forms of dispute resolution should this become not cessary. Article 11 Mutual assistance procedure If both the competent authorities of the parties consider it appropriate to do so, they may agree to exchange technical know-how, develop new audit techniques, identify new areas of non-compliance, and jointly study non-compliance areas. Article 12 Entry into force this Agreement shall enter into force 30 days after receipt of written notification by the latter Party of completion of all legal formalit required for entry into the force. Upon the date of entry into force, it shall have effect: (a) for criminal tax matters on that date; and (b) for all other matters covered in article 1 on that date, but only in respect of the period beginning on the taxabl or after that date or, where there is a period of the taxabl, all charges to tax arising on or after that date. Article 13 Termination Either Party may terminate 1 this agreement by giving notice of termination in writing. Such termination shall become effective on the first day of the month following the expiration of a period of 3 months after the date of receipt of notice of termination by the other Party. All requests received up to the effective date of termination will be deal with in accordanc with the terms of this agreement. 2. If the agreement is terminated the Parties shall remain bound by the provision of article 7 with respect to any information obtained under this agreement. In WITNESS WHEREOF the undersigned have signed this agreement. Done in duplicate at London, this 5th day of September 2012, in the English language.
For the Government of the Republic of Latvia strong Ambassador Eduard Extraordinary and Plenipotentiary of the Republic of Latvia to the United Kingdom of Great Britain and Northern Ireland For the States of Guernsey Peter Harwood Chief Minister a translation by the Government of the Republic of LATVIA and the GĒRNS of the national agreement on Exchange of information for tax purposes subject to the Government of the Republic of Latvia and the Gērns of the countries at international level is an ongoing and active fighting against financial and other crimes , including addressing the financing of terrorism; Considering that, in accordance with the Gērns countries of the United Kingdom of Great Britain and Northern Ireland the authority to have the right to negotiate, conclude, to run and in accordance with the provisions of the Treaty to end the tax information exchange agreement with the Government of the Republic of Latvia; Subject to the national Gērns of 21 February 2002 the political determination to join the Organization for economic cooperation and development (OECD) principles of effective exchange of information; Pursuant to the parties ' desire to enhance and improve the terms and conditions for the exchange of information for tax purposes; Therefore the parties have agreed to conclude the following agreement, to which only the parties undertake obligations: article 1 scope of application of the Treaty

The competent authorities of the Parties shall provide assistance, exchange of information, which is expected in the important national parties for the application of the laws and requirements relating to taxes covered by this agreement. The following information includes information which is expected to determine, calculate and collect such taxes, the recovery of tax recovered and debts (liabilities), or investigate the tax affairs or initiate prosecutions in tax matters. The receiving party shall have no obligation to provide information, not the authorities, nor the person subject to its territorial jurisdiction, actions, or that such persons could not be obtained. Rights and legal guarantees, laid down by the legislation of the requested Party or administrative practices, are applied to the extent that they do not unduly prevent or impede the effective exchange of information. Article 2 taxes covered 1. This contract Agreement will apply to such taxes, imposed by the parties: (a)) Gērns: (i) income tax; (ii) the living space of the profit tax; (b)): (i) corporate income tax; (ii) the tax on micro-enterprises; (iii) the individual income tax; (iv) the tax on immovable property; (v) the value added tax. 2. This agreement shall also apply to any identical taxes, adding to or replacing the existing taxes are introduced after the date of signature of this agreement, or substantially similar taxes, if the parties so agree. In addition, tax, products to which the contract relates, the list may be extended or amended by mutual agreement of the parties to the exchange of letters. The competent authorities of the Parties shall inform each other about substantive amendments in the laws that may affect the parties obligations laid down in the Treaty. Article 3 definitions in this agreement: (a) 1) "Gērns" means the States and Gērns, used in a geographical sense, that under international law, represents the Gērns, Alderney and Herm, including these islands adjacent to the territorial sea; (b)) "Latvia" means the Republic of Latvia and, used in a geographical sense, it represents the territory of the Republic of Latvia and any other Latvian territorial waters adjacent to the territories in which, in accordance with the laws of Latvia and international law can be implemented in Latvia of rights on land and sea depths and natural resources contained therein; (c)) "collective investment fund or scheme" means any thing that is accumulating in the investment, irrespective of the legal form. The term "public collective investment fund or scheme" represents a collective investment fund or plan, if any person (society) can freely buy, sell or delete this Fund or part of the plan, the shares or other interests. "Any person (company)" are free to buy, sell or delete parts of the Fund or the plan, the shares or other interests, if the purchase, sales, or delete rights does not directly or indirectly limited by the limited group of investors. (d)) "the public" means any association or any corporate entity for taxation purposes is considered a corporate Association; e) "competent authority" means: (i) the income tax Gērns, Department head, or his representative; (ii) in Latvia, the State revenue service or its authorized representative, but if Latvia requests information in criminal tax-Attorney-General or his representative may act as the competent authority; f) "criminal laws" means the laws and regulations which, in accordance with national regulations, are treated as criminal acts, whether they are in the tax laws, the criminal code or other laws; g) "criminal proceedings" means tax matters involving intentional conduct before or after the entry into force of this agreement, for which, in accordance with the criminal law of the requesting party, the laws and the threat of criminal liability; h) "information" means any fact, statement, form, document or record; I) "information" means laws, regulations, administrative or judicial process which allows the receiving party to obtain and provide the information requested; j) "parties" means: (i) Gērns; and (ii) Latvia k) "person" includes natural persons, corporations and any other Association of persons; l) "in the main category of shares" means the shares category or categories of shares representing a majority of the voting rights of the company and most of its value; m) "company whose shares have been put on the public turnover" means any company whose main stock categories are listed on the stock exchange, if recognized, any person (society) can freely buy or sell its quoted shares. "Any person (company)" are free to buy or sell shares, if the purchase or sale of rights are not directly or indirectly limited by limited investor group. n) "recognised stock exchange" means any stock exchange agreed on by the competent authorities of the parties; o) "requested Party" means the party to this agreement which is required to provide or has provided information or assistance in response to the request for information; p) "requesting party" means the party to this Agreement shall, for or who have already received the information or assistance from the requested Party; q) "tax" means any tax covered by this agreement. 2. The parties at any time during the application of this agreement, all terms not defined therein, have the meanings they have at the time of the party regulations, unless the context otherwise, besides not risk‐adjusted this side of the relevant tax legislation meaning prevails over other laws and regulations of the party, the intended meaning. Article 4 Exchange of information on request

1. the receiving party the competent authority of the requesting party's request, provide information to implement the objectives referred to in article 1. The following information must be provided regardless of whether the receiving party such information is necessary for the purposes of taxation or action that is examined, would be considered a criminal offence, in accordance with the laws of the requested party if it had taken place in the territory of the requested Party. The requesting party to the competent authority in accordance with this article requires information only if it fails to obtain the requested information within its territory by other means, except where such use would result in a disproportionate burden. 2. If the requested party's competent authority does not have sufficient information to comply with a request for information, the requested Party shall, at its discretion, use all appropriate means of obtaining information necessary for the requesting party to provide the information requested, even if the receiving party such information is not required for the purposes of taxation. 3. The requested party's competent authority in accordance with this article shall provide information, if permitted by its national laws and regulations, with the affidavit or certified copies of the original records, if specifically requested by the requesting party to the competent authority. 4. Each Party shall ensure that its competent authority, the implementing agreement referred to in article 1 objectives, has the power to obtain and provide information on request: (a)), which is a bank, another financial institution and any person acting as an agent or fiduciary, including proxies and trust managers,; (b)) (i) the information on the company, partnerships, Foundation and other individual true beneficiaries, including information on ownership for all such persons who owns property in sequence; (ii) as regards collective investment funds or plans-information on stocks, shares or other interests; (iii) in respect of trusts-for information on the trust, the trust manager of the founder, the trust supervisor, discharge the provider and true beneficiaries; (iv) with regard to foundations, information concerning the Foundation's founders, the Foundation Council or members of the Management Board and the true beneficiaries. This agreement does not create an obligation for a party to obtain or provide information on the ownership for corporations, the shares of which have been put on the public turnover, or public collective investment funds or schemes, unless such information cannot be obtained without creating a disproportionate burden. 5. Any request for information might define in detail, in writing, in particular: (a) the identity of the person) in respect of which a check is being carried out or investigation; (b)) the period for which the information is sought; (c) the nature of the requested information) and form in which the requesting party wishes to receive it; (d)) for taxation purpose for which the information is required; (e)) the reasons why the requested information could be expected in the requesting party's important tax administration and enforcement of the requirements in respect of the person that is identified in this paragraph (a)); f) reasons why the requested information could be or be kept on the receiver side, or be a person subject to the jurisdiction of the requested Party, possession or control, or of such persons; (g)) any of the person's name and address, as long as they know that the controls would be or who would get the requested information; (h) a statement that the request) corresponds to the requesting party's legislation and administrative practice that the requesting party to the competent authority to obtain the information in accordance with its laws and regulations or the usual administrative practice, if the requested information is in the jurisdiction of the requesting party and that it complies with this agreement; I) a statement that the requesting party has used all the means available within its territory to obtain the information, except where it would cause disproportionate burden. 6. the competent authority of the requested Party shall send the information requested by the requesting party as soon as possible. In order to ensure the immediate response of the receiving party: (a) the competent authority of the requesting party) the competent authority shall confirm receipt of the request in writing and communicated to the Requesting Party to the competent authority on request, shortcomings, if any, within 60 days of the receipt of the request; (b) if the requested Party), the competent authority can not get or provide the information within 90 days of receipt of the request in correct form, including if it is facing obstacles in providing the information or it refuses to provide the information, it shall immediately inform the competent authority of the requesting party, explaining the reason for failure, the nature of the obstacles or the reasons for the refusal. Article 5 tax examinations abroad 1. Requesting Party's request, the competent authority of the requested Party the competent authority with the prior written consent of the person to the Requesting Party may allow representatives of the competent authority to come to its territory to interview individuals and examine records. The requesting Party shall notify the competent authority of the requested Party the competent authority for the time and place of the meeting. 2. The requesting party's request, the competent authority of the requested Party, the competent authority of the requesting party may allow representatives of the competent authority to participate in the tax inspection, which is carried out in the territory of the requested Party. 3. If the request referred to in the second paragraph of this article, is satisfied that the receiving party the competent authority carrying out the inspection as soon as possible notify the requesting competent authority of the party of the time and place of the examination, the authority or the officer that is designated to take the test, and the requested party's inspection procedures and conditions. All decisions regarding the test assumes the receiving party carrying out the inspection. Article 6 possibility of declining

1. The requested Party, the competent authority may refuse to provide assistance: (a) if the demand is not made) in accordance with this agreement; (b)) if the requesting party has not exhausted the means available within its territory to obtain the information, except where such use would result in a disproportionate burden; or (c) if the required disclosure) would be contrary to public policy. 2. This agreement does not give rise to the receiving party of any obligation to provide the details that are protected by professional secrecy, legal action or to provide information that may reveal the trade, business, industrial, commercial or professional secret or the transaction process, provided that article 4, fourth paragraph, the information described in only on the basis of this fact, can not be regarded as such a secret or trade process. 3. the request for information may refuse, on the grounds that the tax debt (liabilities), which is the basis for the request is disputed. 4. the receiving party shall not obtain or provide information that the requesting party to the competent authority in accordance with its laws and regulations or the usual administrative practice could not get the requested information would be within the jurisdiction of the requesting party. 5. The requested Party may decline a request for information if the requesting party requests the information for the administration or application of the requesting party's tax laws, rules, or other related requirements that discriminate against nationals of the receiving party or citizen, compared to the requesting party's nationals or citizens, which are located in the same circumstances. Article 7 confidentiality 1 all information received by the competent authority of the party, is considered as confidential as the information obtained in accordance with that party's national regulations. 2. Such information may be disclosed only to persons or authorities (including courts and administrative bodies) involved in the objective referred to in article 1, and the person or institution can use it only for that purpose, including the examination of an appeal. For these purposes, information may be disclosed in open court or in judgements. 3. The following information shall not be used for a purpose that is not referred to in article 1, without the requested party's competent authorities express written consent. 4. information under this agreement is provided to the requesting party may not be revealed to any other jurisdiction. Article 8 costs indirect costs incurred in providing assistance shall be borne by the requested Party, and the direct costs incurred in providing assistance (including costs of engaging external advisors in connection with litigation or otherwise) shall be borne by the requesting party, unless the competent authorities of the parties do not agree on other provisions. The relevant competent authorities shall consult from time to time on the application of this article, and in particular to the beneficiary by the competent authority of the party in advance with consulted the competent authority of the requesting party, if the material is to be expected, the cost of the provision of information in relation to the specific request. Article 9 language requests for assistance and responses to them are drawn up in English. Article 10 mutual conciliation procedure 1. If the difficulties between the parties or there are doubts concerning the application or interpretation of this agreement, the respective competent authorities should seek a mutual agreement to resolve those issues. 2. in addition to the agreements referred to in the first subparagraph of this article, the competent authorities of the parties may mutually agree on the procedures to be applied in accordance with the 4, 5 and 8. 3. the parties may also agree on other ways of resolving disputes, if necessary.
Article 11 procedure for mutual assistance If the competent authorities of both parties consider it appropriate, they can agree on the technical transfer of know-how sharing, development of new audit methods, to identify new areas of non-compliance and to explore common areas of non-compliance. Article 12 entry into force this Agreement shall enter into force 30 days after the last written notification of all required the completion of the legal requirements for its entry into force. With the entry into force, it shall be applied: (a)) regarding criminal matters, from the date of entry into force; (b)) for all other matters covered in article 1 from the date of entry into force, but only in respect of the tax period that starts on or after this date, or, in the absence of the tax period, for all charges to tax arising on or after this date. Article 13 dissolution 1. Either party may terminate this agreement by giving written notice of termination. Such termination shall take effect on the first day of the month following the end of a period of three months after the date on which the other party had received notice of the termination. All requests that are received before the termination date of entry into force, are executed in accordance with the terms of this agreement. 2. If the contract is terminated, the Parties shall comply with article 7 with respect to any information obtained under this agreement. In witness whereof, the undersigned have signed the Treaty. The agreement is drawn up in two copies in the London 2012 on September 5 in English.
The Government of the Republic of Latvia, the Republic of Latvia Strong Eduard Ambassador Extraordinary and Plenipotentiary of the United Kingdom of Great Britain and Northern Ireland on behalf of the national Gērns Peter Harvud head of Government