nature from those used in the collection of its own taxes, or that would be contrary to its sovereignty, security, or public policy.

ARTICLE 27. MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS

The proposed treaty contains the rule found in other U.S. tax treaties that its provisions are not to affect the privileges of diplomatic agents or consular officials under the general rules of international law or the provisions of special agreements. Accordingly, the treaty will not defeat the exemption from tax which a host country may grant to the salary of diplomatic officials of the other country. The saving clause does not apply in full to this article, so that, for example, U.S. diplomats who are considered Finnish residents may generally be protected from Finnish tax.

ARTICLE 28. ENTRY INTO FORCE

The proposed treaty is subject to ratification, acceptance, or approval in accordance with the applicable procedures of each country and the government of each treaty country will notify the other as soon as possible that those procedures have been complied with. The proposed treaty will enter into force 30 days after the later of these notifications.

With respect to Finnish taxes withheld at source, the proposed treaty will be effective for income derived on or after January 1 in the calendar year next following the year in which the treaty enters into force. With respect to other Finnish income taxes and taxes on capital, the treaty is to be effective for taxes chargeable for any taxable year beginning on or after January 1 in the calendar year next following the year in which the treaty enters into force.

With respect to U.S. taxes withheld at source, the proposed treaty will be effective for amounts paid or credited on or after the first day of the second month following the date on the which the treaty enters into force. With respect to other U.S. taxes, the treaty is to be effective for taxable years beginning on or after the first day of January next following the date on which the treaty enters into force.

The present treaty will terminate on the last day on which it has effect in accordance with the provisions described above.

ARTICLE 29. TERMINATION

The proposed treaty will continue in force until terminated by a treaty country. Either country may terminate it by giving written notice through diplomatic channels at least six months before the end of any calendar year following after the period of five years from the date of its entry into force.

A termination will be effective with respect to Finnish taxes withheld at source on income derived on or after January 1 in the calendar year next following the year in which the notice is given. With respect to other Finnish income taxes and taxes on capital, a termination will be effective for taxes chargeable for any taxable year beginning on or after January 1 in the calendar year next following the year in which the notice is given.

With respect to U.S. taxes withheld at source, a termination will be effective for amounts paid or credited on or after the first day of January next following the expiration of the six month period. With respect to other U.S. taxes, a termination is to be effective for taxable years beginning on or after the first day of January next following the expiration of the six month period.

IX. TEXT OF THE RESOLUTION of RatificatION

Resolved, (two-thirds of the Senators present concurring therein), That the Senate advise and consent to the ratification of the Convention between the Government of the United States of America and the Government of the Republic of Finland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital (the Convention), signed at Helsinki on September 21, 1989 (Treaty Doc. 101-11), subject to the following understanding:

That nothing in the Convention requires the United States to allow any person, as a credit against the United States tax on income, any amount of Finnish capital tax.

INCOME TAX CONVENTION WITH THE

KINGDOM OF SPAIN

REPORT

OF THE

COMMITTEE ON FOREIGN RELATIONS

UNITED STATES SENATE

ON

TREATY DOC. 101-16, 101ST CONGRESS, 2D SESSION, INCOME TAX CONVENTION WITH SPAIN, WITH PROTOCOL

JULY 27 (legislative day, JULY 10), 1990.-Ordered to be printed

39-119

U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON: 1990