Page:United States Statutes at Large Volume 49 Part 2.djvu/1865

 RELIEF FROM DOUBLE INCOME TAX-BELGIUM. Arrangement between the United States of America and Belgium for reciprocal relief from double income tax on shipping profits. Ef- fected by exchange of notes, signed Janua7'1J 28, 1936. The American Ambassador (Morris) to the Belgian Prime Minister and Minister for Foreign Affairs and Foreign Oommerce (Van Zeeland) No. 624 EXCELLENCY: EMBASSY OF THE UNITED STATES OF AMERICA, Brussels, January 28,1936. 3871 January 28, 193(. I have the honor to inform you that on condition of reciprocity Arrangement wit.h . . Id' .. .! . . ' Belgium for reclp- cOrpOratIOns, me u mg marItlDle shippmg companies, orgamzed m r b o l C8 1 1 relief.~m dhi~' •• • e Doome ..... ODs p- BelgIUm, the vessels of whIch, documented under the laws of BelgIUm, ping ~otlts. call at American ports, either to load or to unload cargo, or to embark or to land passengers, shall be exempted by the Government of the United States from the payment of taxes on income or profits derived exclusively from the operation of such vessels. This exemption shall apply even though a Belgian corporation or company has an agency or a. branch office in the United States, pro- vided that the activities of the agency or branch office be limited to the direct operation of vessels. By "maritime shipping companies," shall be understood companies which are managed by an "owner" of vessels, the term "owner" including charterers. The Government of the United States, on condition of reciprocity, shall likewise exempt from taxation the incomes of Belgian citizens, not residents in the United States, which consist exclusively of earnings derived from the operation of a. vessel or vessels documented under the laws of Belgium. Income or profits derived from the operation of vessels shall also tnclude income or profits derived from the sale in the United States rf steamship tickets issued by a. Belgian corporation or company. The exemption provided for above shall apply to profits or income received on or after January 1, 1931. The Government of the United States will, however, refund to a. claimant taxes collected by it since January 1, 1931, subject to the statutory period of limitation against refunds. This exemption may be terminated at any time by either Govern- ment on six months' notice given to the other Government. Accept, Excellency, the renewed assurances of my highest con· sideration. His Excellency Monsieur PAUL VAN ZEELAND, Prime Minister and Minister for DAVE H. MORRIS Foreign Affairs and Foreign Commerce.