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United States and Liechtenstein Intergovernmental Agreement on Automatic Exchange of Financial Account Information

The United States and Liechtenstein have signed an intergovernmental agreement (IGA) for automatic exchange of financial account information, outlining their commitment to transparency and cooperation in tax matters. This document outlines the key points of the agreement.

Key Provisions of the Agreement

Good Faith Efforts During Transition Period

• The Competent Authorities intend to take into account each other’s good faith efforts in complying with requirements during the transition period when pursuing enforcement.
• This provision acknowledges that both countries may face challenges during the initial implementation phase and encourages cooperation to resolve any issues that may arise.

Extension of Transition Period

• The transition period can be extended by mutual written decision between the Competent Authorities.
• This flexibility allows both countries to adjust their implementation timelines as needed, ensuring a smooth transition to automatic exchange of financial account information.

Confidentiality and Data Safeguards

• Information exchanged is subject to confidentiality protections, including limitations on use.
• Both Competent Authorities intend to maintain appropriate safeguards and infrastructure for data protection.
• Transmission risk and responsibility are shared between the two authorities.
• Notification of actual or potential breaches must be made promptly.
• This section emphasizes the importance of maintaining confidentiality and ensuring the security of exchanged information.

Costs

• Each authority will bear its own ordinary costs. Extraordinary costs may be allocated by mutual consultation.
• This provision clarifies that each country is responsible for its own expenses related to the agreement, but allows for joint decision-making on extraordinary costs.

Operative Date, Consultation, and Modification

• The Arrangement becomes operative on the later of the date the IGA enters into force or the date it is signed.
• Consultations can be requested at any time for implementation, interpretation, application, or modification.
• Modifications must be made by mutual consent in writing.
• This section outlines the effective date and procedures for consultation and amendment of the agreement.

Publication

• The Arrangement will be publicly available through official publication within 30 days of signature.
• This provision ensures transparency by making the agreement widely available to the public.

Signatories

The United States and Liechtenstein are committed to this agreement, as evidenced by the signatures below:

For the United States Competent Authority: David W. Horton Acting Deputy Commissioner International, Internal Revenue Service

Date

For the Liechtenstein Competent Authority: Irene Salvi Head of International Division, Fiscal Authority of Liechtenstein

Date