Sor Convention on Tax Administration

Sor Convention on Tax Administration

Signed	January 25, 1988 (1988-01-25)
Location	Castillo Monje, Valdavia (Mundaqar)
Parties	Mundaqar

The Sor Convention on Tax Administration is a convention to facilitate the creation and enforcement of bilateral and multilateral tax agreements. The convention was initially developed to govern trade between foreign parties and Mundaqar since business interests between different international healthcare conglomerates had become heavily intertwined. Since its initial success in reducing the tax burden on companies and in decreasing tax fraud, however, the convention has been expanded to allow any member nation to invite new parties. It has also developed several additional provisions clarifying issues of information sharing, law enforcement, and treaty-shopping.

Provisions

The primary objectives of the agreement are to prevent double-taxation of personal incomes and to prevent erosion of either nation's tax base. The most important provisions of the agreement are therefore that personal income is only taxable based on abode (defined as 183+ days residency) and taxation of business income based on where it was earned. Additionally, once ratified, the treaty overrides domestic law and allows the respective nation's tax authorities to negotiate through the convention's Coordinating Body.

Information sharing

The information sharing addendum to the convention provides for exchange of relevant information to the enforcement of domestic tax codes. Information provided under this addendum is confidential and protected by both parties, but can disclosed to courts in order to resolve tax enforcement issues. Because both nations have unique information about both residents and non-residents, the addendum includes access to information about residents of either party or non-residents of either. It is also expected that both parties will aid in investigations by gathering requested information, even if they do not initially have access to it. In addition to information, parties may also request to perform direct examinations of records or even interviews on foreign soil.

Information is not defined in an exhaustive manner, but includes banking details, ownership details of companies, and etc.

Signatories

Nation	Ratification of Original Convention	Ratification of Addenda	Notes
Mundaqar	1988	1995