Reservations under tax assistance treaties restrict administrative cooperation, allowing states to opt out of specified assistance categories.

Article 30 permits a State to declare reservations limiting or excluding specified categories of administrative assistance in tax matters, including non-provision of assistance for particular taxes, refusal to assist in recovery of tax claims or administrative fines, refusal to serve documents or to permit service by post, exclusions for pre-existing tax claims, and temporal limitations on assistance. Only the enumerated reservations are permitted. Reservations made after ratification take effect after a notice period, and reservations may be withdrawn by notification to a Depositary, with withdrawal effective on receipt; a State making a reservation cannot require application of the excluded provision by others.

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