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文档位置:主页 > 国际税收协定库 > 美国 > 正文
  • 发文单位:中华财税网
  • 文    号:
  • 颁布日期:1973-12-04
  • 失效日期:
CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA THE SOCIALIST REPUBLIC OF ROMANIA WITH RESPECT TO TAXES ON INCOME (1)
  
  Convention Signed at Washington December 4, 1973;
  Ratification Advised by the Senate of the United States of America
November 18, 1975;
  Ratified by the President of the United States of America December 15,
1975;
  Ratified by the Socialist Republic of Romania January 31, 1975;
  Ratifications Exchanged at Bucharest January 26, 1976;
  Proclaimed by the President of the United States of America February
25, 1976;
  Entered into Force February 26, 1976;
  Effective January 1, 1974.
GENERAL EFFECTIVE DATE UNDER ARTICLE 27: 1 JANUARY 1974
TABLE OF ARTICLES
Article 1----------------------------------Taxes Covered
Article 2 ---------------------------------General Definitions
Article 3 ---------------------------------Fiscal Residence
Article 4 ---------------------------------General Rules of Taxation
Article 5 ---------------------------------Permanent Establishment
Article 6 ---------------------------------Income from Immovable Property
Article 7 ---------------------------------Business Profits
Article 8 ---------------------------------Shipping and Air Transport
Article 9 ---------------------------------Related Persons
Article 10 -------------------------------Dividends
Article 11 -------------------------------Interest
Article 12 -------------------------------Royalties
Article 13 -------------------------------Capital Gains
Article 14 -------------------------------Independent Personal Services
Article 15 -------------------------------Dependent Personal Services
Article 16 -------------------------------Private Pensions and Annuities
Article 17 -------------------------------Social Security Payments
Article 18 -------------------------------Governmental Functions
Article 19 -------------------------------Teachers
Article 20 -------------------------------Students and Trainees
Article 21 -------------------------------Relief from Double Taxation
Article 22 -------------------------------Nondiscrimination
Article 23 -------------------------------Mutual Agreement Procedure
Article 24 -------------------------------Exchange of Information
Article 25 -------------------------------Members of Diplomatic Missions
and Consular Offices
Article 26 -------------------------------Assistance in Collection
Article 27 -------------------------------Entry into Force
Article 28 -------------------------------Termination
Letter of Submittal---------------------of 11 March, 1974
Letter of Transmittal-------------------of 28 March, 1974
The "Saving Clause"-------------------Paragraph 3 of Article 4

              MESSAGE
              FROM
       THE PRESIDENT OF THE UNITED STATES
             TRANSMITTING
  THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA
AND THE GOVERNMENT OF THE SOCIALIST REPUBLIC OF ROMANIA WITH RESPECT TO
TAXES ON INCOME, SIGNED AT WASHINGTON ON DECEMBER 4, 1973

            LETTER OF SUBMITTAL
                       DEPARTMENT OF STATE,
                       Washington, March 11, 1974.
The PRESIDENT,
The White House.
  THE PRESIDENT: I have the honor to submit to you, with a view to its
transmission to the Senate for advice and consent to ratification, the
Convention between the Government of the United States of America and the
Government of the Socialist Republic of Romania with Respect to Taxes on
Income, signed at Washington on December 4, 1973.
  The Convention deals mainly with Federal income taxes in the case of
the United States and with generally equivalent income taxes specified in
Article 1(1) (a) in the case of Romania. The provision relating to
nondiscrimination applies, however, to taxes of every kind imposed at the
national, state, or local level.
  Largely because of Romania's extensive involvement in international
commerce the Romanian tax system is relatively well developed with regard
to foreign investors. The Romanian tax authorities are familiar with the
concepts of income used in the United States and Western Europe and have
had some experience in their application. It was, therefore, possible to
conclude a convention which, as to the basic provisions governing the
taxation of business income, personal service income and real property
income, as well as the administrative provisions for exchanging tax
information and resolving taxpayer complaints, is similar in all
substantive respects to the conventions recently concluded between the
United States and Western European countries such as Belgium, France and
Norway.
  Romania imposes withholding taxes on dividends, interest, royalties,
rentals and technical service fees. The Convention establishes the present
Romanian tax rate of 10 percent on dividends as an upper limit to the tax
so that in combination with any likely corporate tax (now 30 percent) the
total of Romanian taxes on corporate profits would be fully creditable
against the United States corporate tax. On the other items of income, the
Convention provides for a reduction in Romanian withholding taxesfrom
15 percent to 10 percent on interest (with exemption on interest paid on
loans from, or guaranteed by, the Export-Import Bank or the Overseas
Private Investment Corporation), and from 20 percent to 10 percent on
copyright royalties, including films, and to 15 percent on industrial
royalties. Under the Convention, the United States will observe the same
limits with respect to withholding tax on dividends, interest and
royalties. Moreover, equipment rentals are not to be subject to the
Romanian withholding tax, but will be taxable only if connected with an
office in Romania.
  The Convention also eliminates a Romanian 25 percent tax on income
derived by performers who will be treated under the personal services
provisions of the Convention (Articles 14 and 15).
  A technical memorandum explaining in detail the provisions and effect
of the Convention is being prepared by the Department of the Treasury and
will be submitted to the Senate Foreign Relations Committee for
consideration in connection with the Convention.
  Upon entry into force, this Convention will be effective from January
1, 1974, and will remain in force for a minimum period of five years.
After the initial five-year period it will remain in force indefinitely
until terminated by either State.
  The Department of the Treasury, with the cooperation of the Department
of State, was primarily responsible for the negotiation of this
Convention. It has the approval of both Departments.

Respectfully submitted,
HENRY A. KISSINGER.
Enclosure: Convention.

           LETTER OF TRANSMITTAL
                   THE WHITE HOUSE, March 28, 1974.
To the Senate of the United States:
  I transmit herewith, for Senate advice and consent to ratification,
the Convention between the Government of the United States of America and
the Government of the Socialist Republic of Romania with Respect to Taxes
on Income, signed at Washington on December 4, 1973.
  The Convention was signed during the visit to the United States of the
Romanian President, Nicolae Ceausescu. It is evidence of the continued
improvement and expansion of United States-Romanian relations.
  The primary purpose of this Convention is to promote economic and
cultural relations between the two countries by removing many tax
barriers. The convention follows generally the form and content of
conventions recently concluded between this government and Western
European countries.
  I hope that the Senate will act favorably on this Convention at an
early date.

                            RICHARD NIXON.
     BY THE PRESIDENT OF THE UNITED STATES OF AMERICA
              A PROCLAMATION
CONSIDERING THAT:
  The Convention between the United States of America and the Socialist
Republic of Romania with Respect to Taxes on Income was signed at
Washington on December 4, 1973, the text of which Convention, in the
English and Romanian languages, is hereto annexed;
  The Senate of the United States of America by its resolution of
November 18, 1975, two-thirds of the Senators present concurring therein,
gave its advice and consent to ratification of the Convention;
  The Convention was ratified by the President of the United States of
America on December 15, 1975, in pursuance of the advice and consent of
the Senate, and was ratified on the part of the Socialist Republic of
Romania on December 23, 1974;
  It is provided in Article 27 of the Convention that the Convention
shall enter into force one month after the date of the exchange of
instruments of ratification, with effectiveness with respect to income of
calendar years or taxable years beginning on or after January 1, 1974;
  The instruments of ratification of the Convention were exchanged at
Bucharest on January 26, 1976, and accordingly the Convention enters into
force on February 26, 1976, effective January 1, 1974;
  NOW, THEREFORE, I, Gerald R. Ford, President of the United States of
America, proclaim and make public the Convention, to the end that it shall
be observed and fulfilled with good faith on and after February 26, 1976,
by the United States of America and by the citizens of the United States
of America and all other persons subject to the jurisdiction thereof.
  IN TESTIMONY WHEREOF, I have signed this proclamation and caused the
Seal of the United States of America to be affixed.
  DONE at the city of Washington this twenty-fifth day of February in
the year of our Lord one thousand nine hundred seventy-six and of the
Independence of the United States of America the two hundredth.

By the President:
GERALD R. FORD
HENRY A. KISSINGER
Secretary of State

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