Status of List of Reservations and Notifications at …

1 1 de 9 REPUBLIC OF panama Status of List of Reservations and Notifications at the Time of Signature For jurisdictions providing a provisional list: This document contains a provisional list of expected Reservations and Notifications to be made by the Republic of panama pursuant to Articles 28(7) and 29(4) of the Convention. Deposited on signature on 24 January 20182 de 9 Article 2 Interpretation of Terms notification - Agreements Covered by the Convention Pursuant to Article 2(1)(a)(ii) of the Convention, the Republic of panama wishes the following agreements to be covered by the Convention.

2 No Title Other Contracting Jurisdiction Original/ Amending Instrument Date of Signature Date of Entry into Force 1 Convention between The Republic of panama and Barbados for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Barbados Original 21-06-2010 18-02-2011 2 Convention between The Republic of panama and The Czech Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Czech Republic Original 04-07-2012 25-02-2013 3 Convention entre Le Gouvernement de la Republique de panama et Le Gouvernement de la Republique Fran aise en vue d eviter les doubles impositions et de prevenir l evasion et la fraude fiscales en matiere d impots sur le revenu France Original 30-06-2011 01-02-2012 4 Convention between The Republic of panama and Ireland for the avoidance of double taxation and the prevention of fiscal evasion

3 With respect to taxes on income and capital gains Ireland Original 22-11-2011 19-12-2012 5 Convention between The Republic of panama and The State of Israel for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Israel Original 08-11-2012 30-06-2014 6 Convention between The government of The Republic of panama and The government of The Italian Republic for the avoidance of double taxation with respect to taxes on income and the prevention of fiscal evasion Italy Original 30-12-2010 01-06-2017 7 Convention between The Government of The Republic of panama and The Government of The Republic of Korea for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Korea Original 20-10-2010 01-04-2012 8 Convention between The Republic of panama and the Grand Duchy of Luxembourg for the avoidance

4 Of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital Luxemburg Original 07-10-2010 01-11-2011 Deposited on signature on 24 January 20183 de 9 Deposited on signature on 24 January 20184 de 9 No Title Other Contracting Jurisdiction Original/ Amending Instrument Date of Signature Date of Entry into Force 9 Convenio entre El Gobierno de La Rep blica de Panam y El Gobierno de Los Estados Unidos Mexicanos para evitar la doble imposici n y prevenir la evasi n fiscal en materia de impuestos sobre la renta Mexico Original 23-02-2010 30-12-2010 10 Convention between The Republic of panama and The Kingdom of The Netherlands for the avoidance of double taxatrion and the prevention of fiscal evasion with respect to taxes on income Netherlands Original 06-10-2010 01-12-2011 11 Convention between The Republic of panama and The Portuguese Republic for the avoidance of double

5 Taxation and the prevention of fiscal evasion with respect to Taxes on Income Portugal Original 27-08-2010 10-06-2012 12 Agreement between the Government of The Republic of panama and The Government of The State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Qatar Original 23-09-2010 06-05-2011 13 Agreement between the Government of The Republic of panama and the Government of The Republic of Singapore for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Singapore Original 18-10-2010 19-12-2011 14 Convenio entre la Rep blica de Panam y el Reino de Espa a para evitar la doble imposici n en materia de impuestos sobre la renta y sobre el patrimonio y prevenir la evasi n fiscal Spain Original 07-10-2010 25-07-2011 15 Convention between the Government of The Republic of panama and the Government of The United Arab Emirates for

6 The avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income United Arab Emirates Original 13-10-2012 23-10-2013 16 Convention between The Republic of panama and The United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains United Kingdom Original 29-07-2013 13-12-2013 17 Convention between the Government of The Republic of panama and The Government of The Socialist Republic Of Vietnam for the avoidance of double taxation with respect to taxes on income Vietnam Original 30-08-2016 14-02-2017 Deposited on signature on 24 January 20185 de 9 Article 3 Transparent Entities reservation Pursuant to Article 3(5)(a) of the Convention, the Republic of panama reserves the right for the entirety of Article 3 not to apply to its Covered Tax Agreements.

7 Article 4 Dual Resident Entities Pursuant to Article 4(3)(a) of the Convention, the Republic of panama reserves the right for the entirety of Article 4 not to apply to its Covered Tax Agreements. Article 5 Application of Methods for Elimination of Double Taxation reservation Pursuant to Article 5(8) of the Convention, the Republic of panama reserves the right for the entirety of Article 5 not to apply with respect to all of its Covered Tax Agreements. Article 6 Purpose of a Covered Tax Agreement notification of Choice of Optional Provisions Pursuant to Article 6(6) of the Convention, the Republic of panama hereby chooses to apply Article 6(3).

8 notification of Existing Preamble Language in Listed Agreements Pursuant to Article 6(5) of the Convention, the Republic of panama considers that the following agreements are not within the scope of a reservation under Article 6(4) and contain preamble language described in Article 6(2). The text of the relevant preambular paragraph is identified below. Listed Agreement Number Other Contracting Jurisdiction Preamble Text 1 Barbados desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, 2 Czech Republic desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

9 3 France d sireux de conclure une Convention en vue d viter les doubles impositions et de pr venir l vasion et la fraude fiscales en mati re d imp ts sur le revenu, 4 Ireland desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, 5 Israel desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income; Listed Other Contracting Deposited on signature on 24 January 20186 de 9 Agreement Number Juris