The Federal Ministry of Finance of Germany and the Ministry of Finance of the Netherlands (hereinafter referred to as ‘the Participants’),
Having regard to,
The provisions of Article 9 of the Council Directive number 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation (hereinafter referred to as the ‘Directive’),
The EU Model Instruction for the spontaneous exchange of cross-border rulings and unilateral advance transfer pricing agreements of 2013 (hereinafter referred to as ‘EU Model Instruction’),
The forthcoming changes in EU legislation on exchange of information,
The general principle of reciprocity, which both Participants consider as an important aspect of their mutual cooperation in the field of taxation,
Their desire to,
Be as transparent as possible in the field of taxation
Intensify the spontaneous exchange of information regarding all information with a potential impact on tax assessment(s) executed in the other participating State.
Have agreed the following:
This Memorandum will be evaluated two years after the date of commencement, unless new EU legislation requires an earlier review. However, questions with regard to this Memorandum can be addressed at any time by one of the Participants.