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The Convention On Mutual Administrative Assistance In The Field Of Taxation

Original Language Title: Par Konvenciju par savstarpējo administratīvo palīdzību nodokļu jomā

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The Saeima has adopted and the President promulgated the following laws: The Convention on mutual administrative assistance in tax matters in article 1. With the 2010 amended by the Protocol of 27 May 1988 on 25 January in Strasbourg drafted the Convention on mutual administrative assistance in tax matters (hereinafter referred to as the Convention) with this law is accepted and approved.
2. article. Fulfilment of the obligations provided for in the Convention are coordinated by the Ministry of finance.
3. article. In accordance with article 3 of the Convention, the Republic of Latvia, the competent authority is the Ministry of finance or its authorized representative.
4. article. The Convention applies to the Republic of Latvia, the corporate income tax, individual income tax, value added tax, excise tax and real estate tax.
5. article. In accordance with article 4 of the Convention, the third part of the Latvian Republic reserves the right to inform its residents and nationals on the transfer of information in accordance with the provisions of the Convention and article 7 5.
6. article. The Republic of Latvia shall not apply article 21 of the Convention, the third and the fourth parts relating to the Convention, Member States which acceded to the 1 June 2011 and has been ratified by 27 May 2010 the Protocol on amendments to the Convention.
7. article. In accordance with article 30 of the Convention the first part of the paragraph "a" of the Republic of Latvia does not provide reserves the right, in any form of assistance in respect of article 2 of the Convention following the first paragraph of point "b" (hereinafter referred to as "b") listed another State taxes: 1) mandatory social insurance payments, payable to the Government or under public law established in the social insurance institutions ["b" point (ii)]; 2) property, gift or inheritance taxes, ["b", point (iii) (A)]; 3) taxes on owned motor vehicles or for the use of ["b", (iii) of paragraph (E)]; 4) or use taxes on owned moveable property other than motor vehicles ["b", point (iii) (F)]; 5) any other duties ["b", point (iii) (G)]; 6) point "b" (iii) the categories referred to taxes on other State or political-administrative unit of local government ["b", point (iv)].
8. article. In accordance with article 30 of the Convention, first paragraph, point "b" of the Republic of Latvia reserves the right not to provide assistance or tax claims recovery of administrative penalties for all taxes in respect of which the Republic of Latvia has entered a reservation in accordance with article 30 of the Convention, the first part of point "a".
9. article. In accordance with article 30 of the Convention, first paragraph, point "c" of the Republic of Latvia reserves the right not to provide assistance to any tax claim that on the date of entry into force of the Convention as regards the Republic of Latvia exists or, where the claims relate to taxes in respect of which, in accordance with article 30 of the Convention, the first part of "a" or "b" point is set, there is a disclaimer — before the date by which such reservation is withdrawn.
10. article. In accordance with article 30 of the Convention the first part of the paragraph "d" of the Republic of Latvia reserves the right not to provide assistance in service of documents relating to taxes in respect of which, in accordance with article 30 of the Convention, the first paragraph of point "a" is set out in the disclaimer.
11. article. In accordance with article 30 of the Convention the first part of the paragraph "f" Republic of Latvia reserves the right to apply article 28 of the seventh paragraph, only to provide administrative assistance in respect of the tax period, which began on January 1, on or after 1 January in the third year before the year in which for the Republic of Latvia came into force by 27 May 2010 Protocol amended by Convention.
12. article. As regards the Republic of Latvia, the Convention shall enter into force for the period specified in article 28 and the order, and the Ministry of Foreign Affairs shall notify the official Edition of the "journal".
13. article. The law shall enter into force on the day following its promulgation. With the law put the Convention in English and its translation into Latvian language.
The Parliament adopted the law in 2014 may 8. The President a. Smith in Riga, 14 may 2014 in the CONVENTION ON MUTUAL administrative assistance IN TAX matters preamble the member States of the Council of Europe and the member countries of the Organisation for Economic Co-operation and development (OECD), of this Convention to the signator, Considering that the development of international movement of people, capital, goods and services-although highly beneficial in itself – has increased the possibilities of tax avoidance and evasion and therefore requires increasing the co-operation among tax authorities; Welcoming the various efforts made in recent years to combat tax avoidance and tax evasion on an international level, bilaterally or multilaterally whethers;
Considering that a co-ordinated effort between States is not in order to foster all cessary forms of administrative assistance in matters concerning taxes of any kind whilst at the same time ensuring protection of the adequat rights of taxpayer; Recognising that international co-operation can play an important part in facilitating the proper determination of tax liabilit and in helping the taxpayer to secure his rights; Considering the fundamental principles entitling you every person to have his rights and obligation is determined in accordanc with a proper legal procedure should be recognised as applying to tax matters in all States and that States should endeavour to protect the interests of the taxpayer legitimat, including appropriate protection against discrimination and double taxation; Convinced therefore that States should carry out the measure or supply information, having regards to the not of protecting the confidentiality of cessity information, and taking account of international instruments for the protection of privacy and personal data of flow; Considering that a new co-operative environment has emerged and that it is that (a) the multilaterals desirabl instrument is made available to allow the number of wides in the States to obtain the benefits of the new co-operative environment and at the same time implementations that the highest international standard of co-operation in the tax field; To conclud a convention (menu rngton Line4) on mutual administrative assistance in tax matters, have agreed as follows: Chapter I-scope of the Convention article 1 – object of the Convention and persons covered

1. The Parties shall, subject to the provision of Chapter IV, provide administrative assistance to each other in tax matters. Such assistance may involv, where appropriate, by the measure taken by judicial bodies. 2. Such administrative assistance shall: a. compris exchange of information, including simultaneous tax examination and participation in tax examination abroad; b. assistance in recovery, including measure of conservancy; and (c). the service of documents. 3. A Party shall provide administrative assistance whethers the person affected is a resident or national of a Party or of any other State.
Article 2 taxes covered 1-this Convention shall apply: a. to the following taxes: taxes on income i or profits, (ii) the tax on capital gains. which are imposed separately from the tax on income or profits, (ii). taxes on net wealth, imposed on behalf of a Party; and (b) to the following taxes: (i) tax on income, profits, capital gains or net wealth which imposed on behalf of a political subdivision or local authorities of a Party, (ii) the compulsory social security contributions. payable to general government or to social security institutions established under public law, and (iii). taxes in the other categories, except the customs duties, imposed on behalf of a Party , namely: (A) estate, inheritance, or gift taxes, (B) the tax on property, (C) immovabl general consumption taxes, such as value added or sales tax, (D) specific taxes on goods and services such as excise tax, E tax on the use or ownership of motor vehicles, (F) tax on the use or ownership of movable property other than motor vehicles, (G) any other taxes; IV. tax categories referred to in sub-paragraph (ii). in the above which are imposed on behalf of a political subdivision or local authorities of a Party. 2. The existing taxes to which the Convention shall apply are listed in Annex A in the categories referred to in paragraph 1. The Parties shall notify the Secretary General of the Council of Europe or the Secretary General of the OECD (hereinafter referred to as the "Depositar") of any change to be made to Annex A as a result of a modification of the list mentioned in paragraph 2. Such change shall take effect on the first day of the month following the expiration of a period of three months after the date of receipt of such notification by the Depositary. 4. The Convention shall also apply, as from their adoption, to any identical or substantially similar taxes which are imposed in a Contracting State after the entry into force of the Convention in respect of that Party in addition to or in place of the existing taxes listed in Annex A and, in that event, the Party concerned shall notify one of the to of the adoption Depositar of the tax in question.
Chapter II – General definition in article 3 – Definition 1. For the purpose of this Convention, unless the context otherwise requires: a the term ": the applicant State" and "requested State" mean respectively any Party applying for administrative assistance in tax matters and any Party requested to provide such assistance; (b) the term "tax" means any tax or social security contributions to which the Convention applies to article 2 pursuan; (c) the term "tax claim" means any amount of tax, as well as interest thereon, related administrative costs they incidentals and fine recovery, which are owed table and not yet paid; (d) the term "competent authority" means the person is listed in Annex B and authorities; (e) the term "national" in relations to a Party means: (i) an individual possessing the. all the nationality of that Party, and (ii) all legal persons, partnerships., associations and others entities deriving their status as such in from the law in force in that Party. For each Party that has made a declaration for that purpose, the terms used above will be understood as defined in Annex c. 2. As regards the application of the Convention by a Party, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that Party concerning the taxes covered by the Convention. 3. The Parties shall notify one of the stay of any change to Depositar be made to Annex B and c. Such change shall take effect on the first day of the month following the expiration of a period of three months after the date of receipt of such notification by the Depositary in question.
Chapter III – forms of assistance Section I – exchange of information article 4 – General provision 1. The Parties shall exchange any information, in particular as provided in this section, that is foreseeably relevant for the administration or enforcement of their domestic laws concerning the taxes covered by this Convention. 2. Deleted. 3. Any Party may, by a declaration addressed to one of the Depositar, indicates that, according to its internal legislation, its authorities may inform its resident or national before transmitting information concerning him, in conformity with articles 5 and 7.
Article 5 – Exchange of information on request 1. At the request of the applicant State, the requested State shall provide the applicant with any information the State referred to in article 4, which concerns persons or particular transactions. 2. If the information available in the tax files of the requested State is not sufficient to enable it to comply with the request for information, that State shall take all relevant measure to provide the applicant State with the information requested.
Article 6 – the Automatic exchange of information With respect to the categories of cases and in accordanc with procedures which they shall determin by mutual agreement, two or more Parties shall exchange the information referred automatically to in article 4.
Article 7 – the exchange of information 1 Spontaneo. A Party shall, without prior request, forward to another Party information of which it has knowledge in the following: a. circumstanc the first-mentioned Party has grounds for supposing that there may be a loss of tax in the other Party; b. a person to obtain a liabl tax reduction or exemption from tax in the UN in the first-mentioned Party which would give rise to an increase in tax or to liability to tax in the other Party; c. business dealing between (a) the person liabl to tax in a Party and a person liabl to tax in another Party are conducted through one or more countries in such a way that a saving in tax may result in one or the other Party or in both;
d. a Party has grounds for supposing that a saving of tax may result from artificial transfers of profits within groups of enterprises; e. information forwarded to the first-mentioned Party by the other Party has enabled information to be obtained which may be relevant in assessing liability to tax in the latter Party. 2. Each Party shall take such measure and such procedures as with implementations that not the cessary ensur that information described in paragraph 1 will be made available for transmission to another Party.

Article 8 – simultaneous tax examination 1. At the request of one of them, two or more Parties shall consult together for the purpose of determining cases and procedures for simultaneous tax examination. Each Party involved shall decide whethers or not it wishes to participat in a particular simultaneous tax examination. 2. For the purpose of this Convention, a simultaneous tax examination means through the United Nations between two or more parties simultaneously, each in their the examin its own territory, the tax affairs of a person or persons in which they have a common or related interest, with a view to exchanging any relevant information which they so obtain.
Article 9 – Tax examination abroad 1. At the request of the competent authority of the applicant State, the competent authority of the requested State may allow representatives of the competent authority of the applicant State to be present at the appropriate part of a tax examination in the requested State. 2. If the request is acceded to, the competent authority of the requested State shall, as soon as possible, notify the competent authority of the applicant State about 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 State for the conduct of the examination. All decisions with respect to the conduct of the examination shall be the tax made by the requested State. 3. A Party may communicate one of the of its intention not to Depositar to accept, as a general rule, such requests are referred to as in paragraph 1 (a) Such declaration may be made. or withdrawn at any time.
Article 10 Conflicting information If a Party – receive from another Party of information about a person's tax affairs ' which appear to conflict with information in it to its possession, it shall so advise the Party which has provided the information.
Section II-assistance in recovery article 11 – Recovery of tax claims 1. At the request of the applicant State, the requested State shall, subject to the provision of articles 14 and 15, take the cessary steps to recover tax claims of the first-mentioned State as if they were its own tax claims. 2. The provision of paragraph 1 shall apply only to tax claims which form the subject of an instrument permitting their enforcement in the applicant State, unless otherwise agreed by and between the parties concerned, which are not contested. However, where the claim is against a person who is not a resident of the applicant State, paragraph 1 shall only apply, unless otherwise agreed to between the parties concerned, where the claim may no longer be contested. 3. The obligation to provide assistance in the recovery of tax claims concerning a deceased person or his estate, is limited to the value of the estate or of the property acquired by each beneficiary of the estate, according to whethers the claim is to be recovered from the estate or from the beneficiar a thereof.
Article 12 – Measure of conservancy At the request of the applicant State, the requested State shall, with a view to the recovery of an amount of tax, take a measure of conservancy even if the claim is contested or is not yet the subject of an instrument permitting enforcement.
Article 13 – documents accompanying the request 1. The request for administrative assistance under this section shall be accompanied by: (a) a declaration that the a tax claim concerns a tax covered by the Convention and, in the case of recovery that, subject to paragraph 2 of article 11, the tax claim is not contested, (b) or may not be an official copy of the. the instrument permitting enforcement in the applicant State , and (c) any other document required for. recovery or measure of conservancy. 2. The instrument permitting enforcement in the applicant State shall, where appropriate and in accordanc with the provision in force in the requested State, be accepted, recognised, supplemented or replaced as soon as possible after the date of the receipt of the request for assistance, by an instrument permitting enforcement in the latter State.
Article 14 – time limit 1. Questions concerning any period beyond which a tax claim cannot be enforced shall be governed by the law of the applicant State. The request for assistance shall give in particular concerning that period. 2. Acts of recovery carried out by the requested State in pursuanc of a request for assistance, which, according to the law of that State, would have the effect of suspending or interrupting the period mentioned in paragraph 1, shall also have this effect under the law of the applicant State. The requested State shall inform the applicant State about such acts. 3. In any case, the requested State is not obliged to comply with a request for assistance which is submitted after a period of 15 years from the date of the original instrument permitting enforcement.
Article 15 Priority the tax claim in the recovery of which assistance is provided shall not have in the requested State any priority specially accorded to the tax claims of that State even if the recovery procedure used is the one applicable to its own tax claims.
Article 16 – Deferral of payment of the requested State may allow deferral of payment or payment by instalment if its laws or administrative practice permit it to do so in similar circumstanc, but shall first inform the applicant State.
Section III – service of documents article 17-service of documents 1. At the request of the applicant State, the requested State shall serve upon the addresse documents, including those relating to judicial decision, which emanat from the applicant State and which relate to a tax covered by this Convention. 2. The requested State shall effect service of documents: (a) by a method prescribed by it. in domestic law for the service of documents of a substantially similar nature; b. to the exten the possible, by a particular method requested by the applicant State or the closes to such method available under its own law. 3. A Party may effect service of documents directly through the post on a person within the territory of another Party. 4. Nothing in the Convention shall be construed as invalidating any service of documents by a Party in accordanc with it law. 5. When a document is served in accordanc with this article, it need not be accompanied by a translation. However, where it is satisfied that the addresse of cannot understand the language of the document, the requested State shall arrang to have it translated into or a summary drafted in it or one of its official languages. Alternatively, it may ask the applicant State to have the document either translated into or accompanied by a summary in one of the official languages of the requested State, the Council of Europe or the OECD.
Chapter IV – Provision of relating to all forms of assistance article 18 – Information to be provided by the applicant State

1. (A) the request for assistance shall indicates where the appropriate: a. the authority or agency which initiated the request made by the competent authority; (b) the name, address, or any other particular of assisting in the identification of the person in respect of whom the request is made; (c) in the case of a request for information, the form in which the applicant State wishes the information to be supplied in order to meet its needs; d. in the case of a request for assistance in recovery or measure of conservancy, the nature of the tax claim, the components of the tax claim and the assets from which the tax claim may be recovered; e. in the case of a request for service of documents, the nature and the subject of the document to be served; f. whethers it is in conformity with the law and administrative practice of the applicant State and whethers it is justified in the light of the requirements of article 21.2. g. 2. As soon as any other information relevant to the request for assistance comes to its knowledge, the applicant State shall forward it to the requested State.
Article 19-Deleted article 20 – responses to the request for assistance 1. If the request for assistance is complied with, the requested State shall inform the applicant State of the action taken and of the result of the assistance as soon as possible. 2. If the request is declined, the requested State shall inform the applicant State of that decision and the reason for it as soon as possible. 3. If, with respect to a request for information, the applicant State has specified the form in which it wishes the information to be supplied and the requested State is in a position to do so, the requested State shall supply it in the form requested.
Article 21-Protection of person and limit to the obligation to provide assistance 1. Nothing in this Convention shall be affec the rights and safeguards secured to persons by the laws or administrative practice of the requested State. 2. Except in the case of article 14, the provision of this Convention shall not be construed so as to impost on the requested State the obligation: a to carry out the measure. at variance with its own law or administrative practice or the laws or administrative practice of the applicant State; (b) to carry out the measure. which would be contrary to public policy (ordre public); (c) to supply information which is not. obtainabl is under its own law or its administrative practice or under the law of the applicant State or its administrative practice; d. the supply information which would disclos any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public);
e. to provide administrative assistance if and insofar as it consider the taxation in the applicant State to be contrary to generally accepted taxation principles or to the provision of a convention for the avoidance of double taxation, or of any other convention which the requested State has concluded with the applicant State; f. to provide administrative assistance for the purpose of administering or enforcing a provision of the tax law of the applicant State, or any requirement connected therewith, which-(a) national discriminat against of the requested State as compared with a national of the applicant State in the same circumstanc; g. to provide administrative assistance if the applicant State has not pursued all reasonable measure available under it the law or administrative practice, except where the measure of recourses such would give rise to the disproportionat of difficulty; h. to provide assistance in the recovery in those cases where the administrative burden for that State is clearly disproportionat to the benefit to be derived by the applicant State. 3. If information is requested by the applicant State in accordanc with this Convention, the requested State shall use its information gathering "to obtain the requested information, even though the requested State may not need such information for its own tax purpose. The obligation in the preceding line led is subject to the limitations of the led in this Convention, but in no case shall such limitations from, including in particular those of paragraphs 1 and 2, be construed to permit a State requested it to supply information solely declin because it has an interest in such information from the domestics. 4. In the case of IR the provision of this Convention, including in particular those of paragraphs 1 and 2, be construed to permit a State requested it to supply information solely declin because the information is held by a bank, other financial institution, or a person acting in nomine an agency or a fiduciary capacity or because it relate to ownership interests in a person.
Article 22 – Secrecy 1. Any information obtained by a Party under this Convention shall be treated as secret and protected in the same manner as information obtained under the domestic law of that Party and, to the exten needed to ensur the cessary level of protection of not personal data, in accordanc with the safeguards which may be specified by the supplying Party as required under its domestic law. 2. Such information shall in any case be disclosed only to persons or authorities (including courts and administrative or supervisory bodies) concerned with the assessment, collection or recovery of, the enforcement or prosecution in respect of, or the determination of the appeal in their relations, tax of that Party, or the oversigh of the above. Only the persons or authorities mentioned above may use the information, and then only for such purpose. They may, notwithstanding the provision of paragraph 1, the Court published disclos it in proceedings or in judicial decisions relating to such a tax. 3. If a Party has made a reservation provided for in sub-paragraph (a) of paragraph 1. of article 30, any other Party obtaining information from that Party shall not use it for the purpose of (a) a tax in a category subject to the reservations. Similarly, the Party making such a reservation shall not use information obtained under this Convention for the purpose of (a) a tax in a category subject to the reservations. 4. Notwithstanding the provision of paragraph 1, 2 and 3, information received by a Party may be used for other purpose when such information may be used for for such other purpose-under the law of the supplying Party and the competent authority of that Party such use of authoris. Information provided by a Party to another Party may be transmitted by the latter to a third Party, subject to prior authorisation by the competent authority of the first-mentioned Party.
Article 23 – proceedings 1. Proceedings relating to the measure taken under this Convention by the requested State shall be brough only before the appropriate body of that State.

2. Proceedings relating to the measure taken under this Convention by the applicant State, in particular those which, in the field of recovery, concern the existenc or the amount of the tax claim or the instrument permitting its enforcement, shall be brough only before the appropriate body of that State. If such proceedings with brough, the applicant State shall notify the requested State which shall suspend the procedure pending the decision of the body in question. However, the requested State shall, if asked by the applicant State, take the measure of recovery. the safeguards the conservancy The requested State can also be informed of such proceedings by any interested person. Upon receipt of such information, the requested State shall consult on the matter, if not cessary, with the applicant State. 3. As soon as a final decision in the proceedings has been given, the requested State or the applicant State, as the case may be, shall notify the other State of the decision and the implications which it has for the request for assistance.
Chapter V – the Special provision of article 24 – Implementation of the Convention 1. The Parties shall communicate with each other for the implementation of this Convention through their competent authorities to the respectiv. The competent authorities may communicate directly to for this purpose and may in the authorities the authoris subordinat Act on their behalf. The competent authorities of the two or more parties may mutually agree on the mode of application of the Convention among themselves. 2. Where the requested State consider that the application of this Convention in a particular case would have serious consequences, and the undesirabl of the competent authorities of the requested and of the applicant State shall consult each other and endeavour to resolve the situation by mutual agreement.
3. (A) the co-ordinating body composed of representatives of the competent authorities to be of the Parties shall monitor the implementation and development of this Convention, under the aegis of the OECD. To that end, the co-ordinating body shall recommend any action likely to further the general aims of the Convention. In particular it shall act as a forum for the study of new methods and procedures to increase international co-operation in tax matters and, where appropriate, it may recommend revisions or amendments to the Convention. States which have signed but not yet ratified, accepted or approved the Convention is entitled to be represented at the the meeting of the co-ordinating body as observer. 4. A Party may ask the co-ordinating body to furnish opinions on the interpretation of the provision of the Convention. 5. Where to doubt a difficult or «arise between two or more parties regarding the implementation or interpretation of the Convention, the competent authorities of the Parties shall endeavour to those resolve the matter by mutual agreement. The agreement shall be communicated to the co-ordinating body. 6. The Secretary General of OECD shall inform the parties, and the Signatory States which have not yet ratified, accepted or approved the Convention, is of the opinion furnished by co-ordinating the body according to the provision of paragraph 4 above and of mutual agreements reached under paragraph 5 above.
Article 25-language requests for assistance and answers shall be drawn up of theret in one of the official languages of the OECD and of the Council of Europe or in any other language agreed bilaterally between the Contracting States concerned.
Article 26 – costs Unless otherwise agreed bilaterally will by the parties concerned: (a) the ordinary costs incurred in providing. assistance shall be borne by the requested State; (b) extraordinary costs incurred in providing. assistance shall be borne by the applicant State.
Chapter VI – Final provision Article 27 – Other international agreements or arrangements 1. The possibilities of assistance provided by this Convention do not limit, nor are they limited by, those led in existing or future international agreements or other arrangements between the parties concerned or other instruments which relate to co-operation in tax matters. 2. Notwithstanding paragraph 1, those parties which are member States of the European Union can apply, in their mutual relations, the possibilities of assistance provided for by the Convention in so far as they allow a wider co-operation than the possibilities offered by the applicable European Union rules.
Article 28 – signature and entry into force of the Convention

1. This Convention shall be open for signature by the member States of the Council of Europe and the member countries of the OECD. It is subject to ratification, acceptance or approval. The instrument of ratification, acceptance or approval shall be deposited with one of the Depositar. 2. This Convention shall enter into force on the first day of the month following the expiration of a period of three months after the date on which five States have expressed their consent to be bound by the Convention in accordanc with the provision of paragraph 1. In respect of any member State of the Council of Europe or any member country of the OECD which subsequently express their consent to it be bound by it, the Convention shall enter into force on the first day of the month following the expiration of a period of three months after the date of the deposit of the instrument of ratification, acceptance or approval. 4. Any member State of the Council of Europe or any member country of the OECD which become a Party to the Convention after the entry into force of the Protocol amending the Convention, opened for signature on 27th May 2010 (the "2010 Protocol"), shall be a Party to the Convention as amended by that Protocol, unless they express in a different intention in a written communication to one of the Depositar. 5. After the entry into force of the Protocol, any State which in 2010 is not a member of the Council of Europe or of the OECD may request to be invited to sign this Convention as ratify.â and amended by the Protocol for 2010. Any request to this effect shall be addressed to one of the Depositar, who shall transmit it to the parties. The Depositary shall also inform the Committee of Minister of the Council of Europe and the OECD Council. The decision to invite States which so request to become a Party to this Convention shall be taken by consensus by the parties to the Convention through the co-ordinating body. In respect of any State ratifying the Convention as amended by the 2010 Protocol in accordanc with this paragraph, this Convention shall enter into force on the first day of the month following the expiration of a period of three months after the date of deposit of the instrument of ratification with one of the Depositar. 6. The provision of this Convention, as amended by the Protocol, shall have effect in 2010 for administrative assistance related to a period beginning on or taxabl after 1 January of the year following the one in which the Convention, as amended by the 2010 Protocol entered into force, in respect of a Party, or where there is no period, for the taxabl administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the Convention, as amended by the 2010 Protocol entered into force, in respect of a Party. Any two or more parties may mutually agree that the Convention, as amended by the Protocol, shall have effect in 2010 for administrative assistance related to earlier period or the taxabl charges to tax. 7. Notwithstanding paragraph 6, for tax matters involving intentional conduct which is liabl to prosecution under the criminal laws of the applicant Party, the provision of this Convention, as amended by the Protocol, 2010 IR have effect from the date of entry into force, in respect of a Party in the earlier period of the taxabl relations or charges to tax.
Article 29 Territorial application of the Convention: 1. Each State may, at the time of signature or when depositing its instrument, of ratification, acceptance or approval, specify the territory or territories to which this Convention shall apply. 2. Any State may, at any later date, by a declaration addressed to one of the Depositar, extend the application of this Convention to any other territory specified in the declaration. In respect of such territory the Convention shall enter into force on the first day of the month following the expiration of a period of three months after the date of receipt of such declaration by the Depositary. 3. Any declaration made under either of the two preceding paragraphs may, in respect of any territory specified in such declaration, be withdrawn by a notification addressed to one of the Depositar. The withdrawals shall become effective on the first day of the month following the expiration of a period of three months after the date of receipt of such notification by the Depositary.
Article 30 – reservations

1. Any State may, at the time of signature or when depositing its instrument of ratification, acceptance or approval or at any later date, declare that it reserve the right to: a. not to provide any form of assistance in relations to the taxes of other parties in any of the categories listed in sub-paragraph (b) of paragraph 1 of article. 2 , provided that it has not included any domestic tax in that category under Annex A of the Convention; b. not to provide assistance in the recovery of any tax claim, or in the recovery of an administrative fine, for all taxes or only for taxes in one or more of the categories listed in paragraph 1 of article 2; (c) not to provide assistance in respect of any tax claim, which is in the existenc at the date of entry into force of the Convention in respect of that State or, where a reservation has previously been made under sub-paragraph (a) or (b) above., at the date of withdrawals of such a reservation in relations to tax in the category in question; d. not to provide assistance in the service of documents for all taxes or only for taxes in one or more of the categories listed in paragraph 1 of article 2; e. not to permit the service of documents through the post as provided for in paragraph 3 of article 17; f. Article 7 of their paragraph 28 apply exclusively for administrative assistance related to a period beginning on or taxabl after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol entered into force, in respect of a Party, or where there is no period, for the taxabl administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention , as amended by the 2010 Protocol entered into force, in respect of a Party. 2. other reservations may be made. 3. After the entry into force of the Convention in respect of a Party, that Party may make one or more of the reservations listed in paragraph 1 which it did not make at the time of ratification, acceptance or approval. Such reservations shall enter into force on the first day of the month following the expiration of a period of three months after the date of receipt of the reservation by one of the Depositar. 4. Any Party which has made a reservation under paragraph 1 may wholly or partly withdraw and 3 it by means of a notification addressed to one of the Depositar. The withdrawals shall take effect on the date of receipt of such notification by the Depositary in question. 5. A Party which has made a reservation in respect of a provision of this Convention may not require the application of that provision by any other Party; It may, however, if its reservation is partial, require the application of that provision insofar as it has itself accepted it.
Article 31 – Denunciation 1 Any Party may, at any time, denounc this Convention by means of a notification addressed to one of the Depositar. 2. Such denunciation shall become effective on the first day of the month following the expiration of a period of three months after the date of receipt of the notification by the Depositary. 3. Any Party which denounc the Convention shall remain bound by the provision of article 22 for as long as it is in it will retain possession any documents or information obtained under the Convention.
Article 32 – and their functions 1 Depositar. The Depositary with whom an Act, notification or communication has been accomplished, shall notify the member States of the Council of Europe and the member countries of OECD and any Party to this Convention of: a. any signature; b. the deposit of any instrument of ratification, acceptance or approval; c. any date of entry into force of this Convention in accordanc with the provision of articles 28 and 29; d. any declaration made in pursuanc of the provision of paragraph 3 of article 5 or paragraph 3 of article 9 and the withdrawals of any such declaration; (e) any reservation made in pursuanc of the provision of article 30 and the withdrawals of any reservation effected in pursuanc of the provision of paragraph 4 of article 30; f. any notification received in pursuanc of the provision of paragraph 3 or 4 of article 2, paragraph 3 of article 3, article 29 or paragraph 1 of article 31; g. any other Act, notification or communication relating to this Convention.
2. The Depositary receiving a communication or making a notification in the pursuanc of the provision of paragraph 1 shall immediately inform the other Depositary thereof. In witness whereof the undersigned, being duly authorised, have signed theret the Convention. Established by the Depositar to the 1st day of June 2011 pursuan to article X of the Protocol 4 amending the Convention on Mutual administrative assistance in Tax matters, in English and French, both texts being equally authentic, in two of which the cop to one shall be deposited in the archives of each Depositary. The stay shall transmit a certified Depositar copy to each Party to the Convention as amended by the Protocol and to each State entitled to become a party. May 29, 2013. For the Government of the Republic of Latvia Mrs. Sunita Pavļut-Deslandes the Ambassador Extraordinary and Plenipotentiary of the Republic of Latvia to the Republic of France Annexe A Taxi covered article 2, paragraph 1 (a). i: – income tax; -corporation tax; Article 2, paragraph 1 (a) (ii): – article 2., paragraph 1 UR.a.iii:-article 2, paragraph 1 (b):-article 2 i, paragraph 1 (b). (ii):-article 2, paragraph 1 (A): UR.b.iii-article 2, paragraph 1 (B): UR.b.iii-tax on property immovabl article 2, paragraph 1 (C): UR.b.iii-value-added tax article 2, paragraph 1 D: UR.b.iii-excise taxes article 2, paragraph 1 (E):-UR.b.iii. Article 2, paragraph 1 (F):-UR.b.iii. Article 2, paragraph 1 (G) UR.b.iii. :-Article 2, paragraph 1 (b) of Annex iv (B) Competent authority: the Ministry of Finance of the Republic of Latvia or its authorised representative.
   
The unofficial translation of the Latvian language in the Convention on mutual administrative assistance in tax matters in the preamble

The Member States of the Council of Europe and the Organization for economic cooperation and development (OECD) Member States which have signed this Convention, taking into account that persons, capital, goods and services, the development of an international movement – although very useful as such – has increased the chance of avoiding paying taxes, it is necessary to expand cooperation between tax administrations, welcoming the recent years bilateral and multilateral steps already taken various measures at the international level the fight against tax evasion given that between countries requires concerted action to promote all types of administrative cooperation with regard to all types of taxes, at the same time ensuring an appropriate taxpayer protection, recognizing that international cooperation can play an important role in determining the proper tax liability and the provision of assistance to taxpayers in protection of the law, given that, in accordance with the appropriate legal procedure laid down guiding principles that determine each person's rights and obligations, be recognized as applicable in the field of taxation in all countries, and these countries must ensure taxpayers ' legal rights protection, including appropriate protection against discrimination and double taxation, thus making sure that countries should take measures or information is to be provided, taking into account the protection of confidentiality of information and privacy and personal data protection of the flow of international funds in view of the fact that a new environment of cooperation and it is desirable that is made available to the multilateral measures to most countries would benefit from the new environment of cooperation and at the same time, to introduce the highest standards of international cooperation in the field of taxation, reaffirming willingness to conclude the Convention on mutual administrative cooperation in the field of taxation, agree on the following: chapter I scope of the Convention article 1 subject-matter and parties to the Convention to which it applies 1. in accordance with the provisions of chapter IV, the Parties shall provide mutual administrative assistance in tax matters. If necessary, such assistance may include legal measures by the authorities. 2. This administrative assistance shall include: (a)) the exchange of information, including simultaneous tax examinations and membership of the tax examination abroad; b) duties, including funds to conservation measures; and (c)) the service of documents. 3. the Party shall provide administrative assistance, regardless of whether the person involved is a party or a resident of any other country or national.
Article 2 taxes covered by the Convention, this Convention 1 applies in respect of: (a)) the following taxes: (i) the income or profit tax, (ii) the capital gains tax, which is charged separately from the income or profit taxes, (iii) the common property (the welfare) taxes imposed by the parties; and (b)) the following taxes: (i) income, profit, capital gains or the common property (the welfare) taxes on the party political or administrative units of local government, (ii) compulsory social insurance payments, payable to the Government or under public law established in the social insurance institutions, and (iii) other categories of taxes, other than customs duties, imposed by the parties, namely: a. the property, inheritance or gift taxes, b. real estate taxes , C. General consumption taxes, such as value added or sales taxes, d. specific goods and services taxes, such as excise duties, E. taxes on owned motor vehicles or for use, taxes on the use F or owned the property, other than motor vehicles (G). any other duties; (iv) (iii) the categories referred to in taxes on the party's political and administrative unit or municipality. 2. with regard to the categories referred to in the first paragraph of the existing taxes to which the Convention applies are listed in annex a. 3. the Parties shall inform the Secretary-General of the Council of Europe or the OECD Secretary-General (hereinafter referred to as "the depositary") about any changes to be made in connection with Annex A amendments to the list referred to in paragraph 2. These changes shall enter into force on the first day of the month following the period of three months from the date of the depositary has received such notification. 4. Once adopted, the Convention shall apply also to any identical or substantially similar taxes which, supplementing or replacing the existing listed in Annex A to the tax, are introduced in a Contracting State after the date on which the Convention enters into force for that party, in the end, the party concerned shall notify one of the depositaries of the introduction of the tax.
Chapter II General definitions article 3 definitions

1. unless the context is not otherwise specified, the risk‐adjusted in this Convention: a the term ") requesting country" and "country of destination" means any party that requires you to provide administrative assistance in the field of taxation and any party that is requested to provide administrative assistance in the field of taxation; (b)), the term "tax" means any tax or social security contributions, to which, in accordance with paragraph 2 of the Convention applies; (c)), the term "tax claims" means any amount of unpaid tax, plus interest, related administrative penalties and the amount of recovery; (d)) the term "competent authority" means the persons and institutions listed in Annex B; (e)) with respect to a party, the term "national" means: (i) any natural person who has the nationality of the parties, and (ii) any legal person, partnership, association or other entity that, in accordance with the legislation of the parties must be considered. Each party that has submitted a notification for this purpose, the terms above should be understood as defined in annex c. 2. the application of this Convention to each of the parties, all the undefined terms have the meaning they have in the laws of that party in respect of taxes covered by the Convention, unless the context otherwise not risk‐adjusted. 3. the Parties shall notify one of the depositaries of any annexes B and C changes. These changes came into force on the first day of the month following a period of three months after the date on which the Depositary Government has received the following statement.
Chapter III, section I of the forms of assistance, the exchange of information article 4 General provisions 1. Parties under this section, the exchange of information, which is expected in the important national legislation of the parties to the application or enforcement of laws relating to the taxes to which this Convention applies. 2. Turned off. 3. Each Party may send one of the depository of official notification that States that, in accordance with its national regulations, these parties may inform the authorities before its residents or nationals of a State, of information relating to the transfer of such persons, in accordance with article 5 and 7.
Article 5 Exchange of information upon request 1. The requested State shall, at the request of the requesting State shall provide a requesting country any information referred to in article 4 relating to particular persons or transactions. 2. If the requested State does not have enough relevant tax information to comply with a request for information, that State shall take all necessary measures to provide the information requested by the requesting State.
Article 6 Automatic exchange of information in two or more parties automatically referred to in article 4 Exchange of information concerning mutually agreed way to specific cases and in accordance with the mutual agreement procedures laid down in the road.
Article 7 Spontaneous exchange of information 1. Party without prior request, provide information to the other party that it has become known, in the following cases: (a) the first mentioned party) has reason to believe that the other party may incur tax losses; (b)) the taxable person applies tax relief or exemption from tax in the first half, which can generate taxation or tax increases on the other side; (c) the commercial transactions between and) the other taxable persons are performed by one or more States, thereby reducing the amount of tax in one or the other, or both sides. d) party has reason to believe that a saving of tax may result from artificial transfers of profits within groups of enterprises; e) information that one of the Parties sent the first mentioned party has enabled information to be obtained which may be relevant in assessing liability to tax in the second half. 2. each Party shall take the appropriate measures and procedures necessary to ensure that the information specified in paragraph 1, it is possible to provide to the other party.
Article 8 simultaneous tax examinations 1. At the request of a party, two or more Parties shall consult in order to agree on a simultaneous tax examinations and procedures. Each participating party to decide whether it wants or does not want to participate in the simultaneous tax examination concerned. 2. for the purposes of this Convention, "simultaneous tax examination" means an agreement between two or more parties, each in its own territory with regard to tax issues carry one or more persons at the same time checks for which they have a common or related interests, in order to carry out any important information that they could obtain, Exchange.
Article 9 tax examinations abroad 1. Requesting the competent national authorities of the requested State, the competent authority may authorise the requesting competent authority of the country of representatives to participate in the beneficiary country concerned tax checks. 2. If the request is approved, the recipient of the national competent authority as soon as possible notify the Requesting competent authority of the country of the time and place of the examination, the authority or the officer that is designated to take the test, and the requested State inspection procedures and conditions. All decisions regarding the tax inspection shall adopt the requested State. 3. a party may notify the Depositary of its one intent not to accept the request set out in paragraph 1. The following statement can be expressed or withdrawn at any time.
Article 10 Conflicting information if a party receives from the other side of information information on personal tax matters, which is different from the information in its possession, it shall notify the party who provided the information.
Section II duties of ASSISTANCE article 11. Tax recovery claims

1. at the request of the requesting State, the requested State, in accordance with articles 14 and 15 of the rules, shall take the necessary measures for the former State tax collection in the same way as tax claims would be the recipient country due to tax claims. 2. the provisions of paragraph 1 are only applied to the tax claims, which is recovered in the requesting country, and, with the exception, unless the parties involved are not mutually agreed upon other conditions which have not been challenged. However, if a claim refers to a person who is not a resident of the requesting State and the participating parties shall agree on other provisions, the provisions of paragraph 1 are only applied to claims that can not longer be challenged. 3. the obligation to provide tax assistance for the recovery of claims relating to deceased persons or the property is limited to the property or property received by each beneficiary value depending on whether the recovery will be made from the estate or beneficiary.
Article 12 resources conservation measures At the request of the requesting State, the requested State in order to recover the amount of tax, take measures for the conservation of resources, even if the drive is contested or is not yet on the debt issued to the Executive document permitting its recovery.
Article 13 Request for accompanying documents 1. in accordance with this section the specific requests for administrative assistance shall be accompanied by: (a) confirmation that tax) debt (liabilities), the relationship to the taxes covered by the Convention and, in the event that recovery in accordance with paragraph 2 of article 11, it is not or cannot be disputed. (b) the implementation of the official document) that requesting country the drive, the copy, and (c)) the other documents needed for recovery or conservation measures. 2. the Executive document that a requesting country allow the recovery of the debt, and in accordance with the national rules in force are accepted, recognized, supplemented, or as soon as possible after receipt of the request for administrative assistance, replaced by Executive document permitting the collection of the requested State.
Article 14 Term 1 for any length of time after which a tax claim cannot be recovered by the requesting country's laws and regulations. Requests for assistance indicate the specific size for this period. 2. the enforcement measures taken in the requested State shall comply with the request for assistance, in accordance with the laws of that State, might affect the period referred to in paragraph 1, it stopped or suspended, the applicant also refers to the national legislation. The requested State shall inform the requesting country of the said regulations. 3. in any case, the receiving State has the obligation to comply with a request for assistance that is requested after 15 years period after the settlement document, which allows the recovery of the debt, the date of issue.
Article 15 benefits of tax collection of claims in respect of which assistance is provided, the requested State shall not be granted any advantage compared with the recovered tax claims, even if the recovery procedure used is the same one it uses in respect of its tax recovered.
Article 16 deferral, the requested State, if it complies with its laws or administrative practice in similar situations, may be allowed to defer payment of debt or to pay for it, but you must inform the requesting country.
(Iii) the service of documents article 17 1 of the Service By the applicant State the requested State shall be transmitted to the recipient of the document, including judicial decisions emanating from the requesting State and relating to the taxes to which the Convention applies. 2. the beneficiary countries shall ensure: (a) the transmission of documents) in accordance with its national legislation on the procedure essentially similar to the transmission of documents; (b)) to the extent possible, according to the country of the applicant requested method, or in accordance with the national laws in essence laid down similar methods. 3. a party may make a document sent by post directly to the person in the territory of the other party. 4. Nothing in this Convention may be interpreted not as forbidding a party to issue documents in accordance with its laws and regulations. 5. documents issued in accordance with this article, they do not need to be accompanied by a translation. However, if it is established that the recipient might not understand the language in which the document is drawn up, the requested State shall provide a translation of the document or prepare its summary of its official or one of its official languages. As an alternative, it may ask the requesting country to provide a translation of the document, or add a summary in one of the beneficiary country, or the OECD Council of Europe official languages.
Chapter IV conditions for all types of assistance article 18 the information you provide to the requesting country 1. Requests for assistance, if necessary, indicate: (a) the authority or agency), which proposed to make a request to the competent authority; (b)) a person subject to the request-name, address, or any other important information that allows to identify it; c) in the case of requesting information, the manner in which the requesting State wishes to receive the information that meets its needs; d) recovery and conservation measures in the case of a request for assistance-tax claim in the nature of the ingredients and the assets of which may be tax debt; e) in the case of service of documents-the nature and content of the document; f) confirmation that the aid complies with the request of the requesting State and the laws and administrative practice and that it conforms with article 21, paragraph 2, subparagraph (g). 2. as soon as any other information that is essential to the execution of the request for assistance, is known, the requesting country shall forward it to the requested State.
Article 19 article 20 off a reply to a request for assistance

1. If a request for assistance is appropriate, the requested State shall inform the requesting country about the activities and the results of assistance as quickly as possible. 2. If the request is refused, the requested State shall as quickly as possible inform the requesting country of the decision taken and the reasons for it. 3. If a request for information to the requesting country has pointed out the way in which it wants to receive information and the receiving State has the capability to provide it in a way, the requested State shall provide it as requested.
Article 21 of the protection of persons and the obligation to provide assistance restrictions 1. Nothing in this Convention shall affect the rights and protection of which the person provides the requested State in accordance with its regulations or administrative practice. 2. in no case shall the provisions of this Convention, the exception laid down in article 14, may not explain that they impose on the beneficiary country: (a) the obligation) to take measures contrary to its legislation or administrative practices of the requesting State or the legislation or administrative practice; (b)) to take measures which would be contrary to public policy (ordre public); (c)) to provide information that is not available under its laws or administrative practices of the requesting State or the legislation or administrative practice; (d)) to provide information that can reveal any trade, business, industrial, commercial or professional secret or process a transaction, or to provide information, the disclosure of which would be contrary to public policy (ordre public); (e)) to provide administrative assistance if and in so far as it is considered that the imposition of such duties in the requesting country is contrary to generally accepted taxation principles or Convention on double taxation rules or any other provisions of the Convention that the requested State has concluded with the requesting country; (f)) to provide administrative assistance to administer or apply the requesting State tax laws, rules, or other related requirements that discriminate against nationals of the requested State to the Requesting State in comparison with the nationals of the country, located in the same circumstances; (g)) to provide administrative assistance if the requesting country has used all possible measures available under its laws or administrative practice, except if such measures would lead to disproportionate difficulties; (h)) to provide assistance for recovery in cases where the administrative burden this State is clearly disproportionate to the benefits accruing to the requesting country. 3. If in accordance with this Convention in the requesting country requests information, the requested State shall use its information gathering measures to obtain the requested information, even if the recipient of such information is necessary for the purposes of taxation. Limits laid down in the Convention apply to those in the previous sentence, but in no case shall such limitations, in particular points 1 and 2 must not be set to explain the way that they allow the beneficiary countries to refuse to provide information only so that this information does not require the same taxation needs.
4. in no case shall the provisions of this Convention, in particular paragraphs 1 and 2 may not be the rules, explain that they requested the State would cover the provision of information only because the information holder is a bank, another financial institution, its representative or person acting as trustee or broker, or because it refers to property rights in person.
22. Article 1 of the Secret all information in accordance with this Convention, a party is considered to be received on the same secret and protected, as the information obtained in accordance with that party's national regulations and, in so far as this is necessary to ensure the required level of protection of personal data, in accordance with the protection measures, which you can specify the party provide the information laid down in its national legislation. 2. in any case, such information may be disclosed only to persons or authorities (including courts and administrative bodies or uzraugošaj), which is involved in the calculation of this party, charging or recovery, law enforcement or trials or appeals. Only the above mentioned persons or authorities may use this information solely for the purposes described above. Them, regardless of the laid down in the first subparagraph, it may be disclosed in open court or court judgements relating to such taxes. 3. If a party has made a reservation pursuant to article 30 (1) (a). the point, then the other party that receives information from this side it is not used for reservations in the taxes category. Similarly, the party that made such a reservation may not be used in accordance with the Convention, the information received regarding the reservations included in the taxes category. 4. Regardless of the 1, 2, and 3. the conditions of paragraph, information that the party has received, can be used for any other purpose, if the use of the information for other purposes meets the party providing the information, legislation and the competent authority of the party, and has given permission to use it that way. The information provided by one party to the other party, may be transferred to any other party, if the party the former competent authority has previously given such permission.
Article 23 requirements

1. requirements for the requested State of the measures taken under this Convention, that State should be the only way the institutions concerned. 2. requirements for requesting the national measures taken under this Convention, especially those relating to the performance of the drive, the document permitting the recovery of the debt or claim of the existence of the tax or the amount is to be the only way that State institutions concerned. If such a claim is submitted, then the requesting country shall inform the beneficiary country that initiated procedures to the limits of the authority decision. However, the requested State shall, at the request of the requesting State, shall take measures for the conservation of resources, drive. Any interested party may inform the recipient countries of those claims. When you receive this information, if necessary, the requested State may consult with the requesting country on receipt of such information. 3. as soon as the final decision on a claim is accepted, the requested State or the requesting country, depending on the circumstances, inform other countries about this decision and its impact on the request for assistance.
Chapter v special provisions article 24 implementation of the Convention, the Parties shall contact 1 with one another on the implementation of the Convention through their competent authorities. For this purpose, the competent authorities may communicate directly or empower the authorities to act on their behalf. Two or more of the competent authorities of the parties may mutually agree on the application of the Convention between provisions. 2. If the requested State considers that the application of the Convention in a given case can lead to serious and undesirable consequences, the beneficiary country or of the requesting State shall consult the competent authorities and trying to resolve this situation by agreement. 3. The coordinating body, composed of representatives of the competent authorities of the parties, the Chair of the OECD monitors the application and development of the Convention. The coordinating body recommended possible measures to implement the objectives of the Convention. In particular, it acts as a forum in which identify and explore new methods and processes to expand international cooperation in the field of taxation, and, if necessary, it can recommend repairs or amendments to the Convention. The party, which has signed but not yet ratified, accepted or approved the Convention, shall be entitled to participate in meetings of the coordinating body, as an observer. 4. a party may request the coordinating authority to provide views on the implementation of the provisions of the Convention. 5. If two or more parties have difficulty or doubt as to the interpretation or implementation of this Convention, the competent authorities of the parties to the agreement by trying to resolve the situation. The agreement must inform the coordinating body. 6. the Secretary-General of the OECD shall inform the parties and the States which have signed but not yet ratified, accepted or approved the Convention adopted by the coordinating body referred to in paragraph 4 and the prices referred to in paragraph 5 of the reciprocal agreements.
Article 25 language requests for assistance and responses to them are to be provided in any of the OECD and the Council of Europe's official languages or in another language which is agreed by bilateral Contracting States. Article 26 costs unless the parties have agreed otherwise, the: a) assistance during the current expenses shall be borne by the requested State; (b)) to the exceptional costs incurred during shall be borne by the requesting country.
Chapter VI final provisions article 27 other international agreements or arrangements 1. assistance under this Convention is without prejudice to the possibility of the provision, or they may be restricted to existing or new international agreements or other arrangements between States, as well as with other cooperation mechanisms in tax matters. 2. Notwithstanding paragraph 1, the parties which are Member States of the European Union can apply in their mutual relations, the possibility of assistance laid down in the Convention, if they allow for more cooperation, as provided for in the applicable rules of the European Union.
Article 28 of the Convention signing and entry into force 1 this Convention shall be open for signature by the Member States of the Council of Europe and OECD member countries. It is subject to ratification, acceptance or approval. One of the depositary must be deposited with the instrument of ratification, acceptance or approval.
2. this Convention shall enter into force on the first day of the month following a period of three months after the date on which five States referred to in paragraph 1, in the order have expressed their consent to be bound by the Convention. 3. In respect of any of the Council of Europe and OECD member, who then declares his agreement to accede to the Convention, the Convention entered into force on the first day of the month following the period of three months after the date of deposit of the instrument of ratification, acceptance or approval. 4. the Council of Europe or Any OECD member which becomes a party to the Convention after the 27 May 2010 open for signing Protocol in amending the Convention (hereinafter referred to as the 2010 Protocol) entered into force, is with the 2010 Convention as amended by the Protocol, the party unless it expresses a different intention in writing informing one of the depositaries. 5. by 2010, the entry into force of this Protocol, any State which is not a Council of Europe and OECD Member State may request the invite to sign it with the 2010 Convention as amended by the Protocol. All such requests must be sent to the depositary, which shall forward it to the party. The depositary shall also inform the Committee of Ministers of the Council of Europe and the OECD Council. The decision on which countries have expressed their willingness to become a party to the Convention, inviting is adopted by agreement between the parties with the coordinating institution. For any State which ratifies the Protocol amended on 2010 Convention in accordance with this paragraph, the Convention shall enter into force on the first day of the month following the period of three months after the date of deposit of the instruments of ratification of the article is to one of the depositaries.

6.2010 Convention as amended by the Protocol's provisions relating to administrative assistance shall take effect with the tax period, which begins on January 1, or after the calendar year following the year in which the Protocol by 2010, the amended Convention entered into force in the country concerned, or if there is no tax period, for administrative assistance relating to taxation, the calendar year 1 January, or after the following the year in which the Protocol amended by 2010. entry into force of the Convention in the country concerned. Any two or more States may mutually agree that the 2010 Protocol of the amended Convention on administrative assistance shall enter into force on the previous tax period or taxation. 7. Notwithstanding paragraph 6, with the 2010 Convention as amended by the Protocol's provisions relating to tax things that involve intentional conduct, for which, in accordance with the criminal law of the requesting party legislative criminal liability, with respect to a party applies to the date of entry into force, with respect to the previous tax period or taxation.
Article 29 territorial application of the Convention 1 each at the time of signature or when depositing its instrument of ratification, acceptance or approval article can specify the territory or territories to which this Convention applies. 2. Each country at any later time by notification to one of the depositaries, extend the application of the Convention to other areas that are specified in the notice. For these territories, the Convention entered into force on the first day of the month following the period of three months after the date on which the Depositary Government has received the following statement. 3. Any, according to the two previous posts, submitted a statement which lists the territory can be undone by one of the depositaries of the sent message. Withdrawal shall take effect on the first day of the month following a period of three months after the date on which the Depositary Government has received the following statement.
Article 30 reservations 1. Each country, at the time of signature or ratification, acceptance or approval of the article at the time of the deposit, or at a later time, you can announce that its Disclaimer of their rights: (a)) not to provide any kind of assistance in relation to the other parties on article 2, paragraph 1 (b)) tax listed in the categories, on condition that it is not in Annex A of the Convention included any domestic taxes in this category; (b)) does not provide assistance for the tax claim or recovery of administrative penalties for all article 2, paragraph 1 of the taxes, or only for one or more categories for these duties; (c)) does not provide assistance as regards tax claim in regards to this country exists on the date of entry into force of the Convention, or, if in accordance with (a)) or (b)) is a disclaimer, which exists before the date by which the following reservation withdrawn for the appropriate tax category; (d)) not to provide assistance in service of documents relating to all article 2 taxes referred to in paragraph 1, or only for one or more categories for these duties; e) not to carry out the service of documents by post, as defined in article 17, paragraph 3; (f)) to apply article 28, just to give administrative assistance in respect of the tax period that begins on January 1, or after the third year preceding the year in which the 2010 Convention as amended by the Protocol entered into force for that country, or if for administrative assistance regarding taxation is not a tax period, with January 1 or after the third year, the year before with the 2010 Convention as amended by the Protocol entered into force for that country. 2. other reservations can not be fixed. 3. After the entry into force of the Convention with respect to a party, it may order one or more of the reservations referred to in paragraph 1, which it is not defined by the instrument of ratification, acceptance or approval. These reservations entered into force on the first day of the month following the period of three months after the date on which one of the depositaries of the reservation has been received. 4. Each Party shall, in accordance with paragraphs 1 and 3 are determined by the disclaimer may wholly or partly withdraw a statement to one of the depositaries. The cancellation came into effect on the date when the notification is received by the Depositary. 5. Each party that has adopted a reservation concerning the provisions of this Convention, may not require any other party to apply these provisions, if the reservation is partial, a party may require the application of these rules in so far as it itself has adopted them.
Article 31 denunciation (cancellation) 1. either party may at any time terminate this Convention sends a message to one of the depositaries. 2. the termination shall take effect on the first day of the month following a period of three months after the date on which the Depositary Government has received the following statement. 3. any party which terminates the Convention remain bound by the provisions of article 22 as it is in possession of any documents or information obtained under this Convention.
Article 32 Depositary and its functions 1. Depositary who has received a written note or notice, inform the Council of Europe, the OECD and Member States parties to this Convention of: a any signature;) (b)) the instruments of ratification, acceptance or approval of the deposit; (c) any date) when this Convention in accordance with articles 28 and 29 has entered into force; d) any notification made under paragraph 3 of article 4 and paragraph 3 of article 9 and of all such notifications withdrawn; e) all reservations laid down in accordance with article 30 and in accordance with article 30, paragraph 4 of the reservation cancellation; f) any notification received in accordance with article 2, paragraph 3 or 4, article 3, paragraph 3, article 29 and article 31 (1) of the regulation; g) any document, note or communication relating to this Convention.

2. The depository that receives or gives notice in accordance with the provisions of paragraph 1, it shall immediately inform the other depositary. In witness thereof, the undersigned, being duly authorised, have signed this Convention. Convention drawn up on the depositary 1 June 2011 under the Protocol amending the Convention on mutual administrative assistance in tax matters in article 4 X in English and French languages, both texts being equally authentic, in two original copies of which one shall be deposited in the archives of the depository of each. The depositary shall send to each party by the year 2010, as amended by the Protocol of a certified copy of the Convention and to any State entitled to become a party. 29 may 2013. The Government of the Republic of Latvia, the Republic of Latvia and the Ambassador extraordinary Plenipotentiary in the Republic of France Pavļut-Lisa Deslandes annex taxes covered by the Convention in article 2 (a)) of the first subparagraph of point (i):-corporate income tax; -personal income tax; Article 2 (a) of the first subparagraph of point (ii)):-article 2, first paragraph, point (a)) (iii):-article 2 (b) of the first subparagraph of point (i)):-article 2 (b) of the first subparagraph of point (ii)):-article 2, first paragraph, point (b)) (iii) of subparagraph (A), section:-article 2, first paragraph, point (b)) (iii) of subparagraph (B), section:-real estate tax. Article 2, first paragraph, point (b)) (iii) of subparagraph (C), section:-value added tax. Article 2, first paragraph, point (b)) (iii) of subparagraph (D), section:-excise duties Article 2) (b) of the first subparagraph point (iii) of subparagraph (E), section:-article 2, first paragraph, point (b)) (iii) of subparagraph (F), section:-article 2, first paragraph, point (b)) (iii) of paragraph (G) of section:-article 2 (b) of the first subparagraph of point (iv)):-Annex B the competent authority of the Republic of Latvia, the Ministry of finance or its authorized representative.