Treaty on Global Currency Transactions Tax

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Treaty on Global Currency Transactions Tax

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PART II Currency [Exchange] Transaction Tax

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TITLE X PERSONS LIABLE FOR PAYMENT

TITLE X PERSONS LIABLE FOR PAYMENT

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ARTICLE 13

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§1 Taxable persons who carry out taxable transactions shall be liable to pay tax to the authorities of the Contracting State. The Contracting States may also provide that someone other than the taxable person shall be held jointly and severally liable for payment of the tax when the relevant transaction involves a currency of a Contracting Party.

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§2 When the taxable transaction is effected by a taxable person resident abroad Contracting States may adopt arrangements whereby tax is payable by someone other than the taxable person residing abroad. Inter alia a tax representative or other person for whom the taxable transaction is carried out may be designated as such other person.

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§3 Paragraphs 1 and 2 are not applicable and as than the tax shall be payable by the financial intermediary if at least one of the taxable persons called upon a financial intermediary for the exchange transaction and provided the financial intermediary has been recognised as such by the competent authority of a Contracting State. This authority may subject the recognition to financial guaranties.

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