Austria

This Convention applies to persons resident in one or both Contracting States.

1. This Convention applies to income and property taxes payable by each Contracting State, its political or administrative subdivisions or its local authorities, irrespective of the system of its levy.

2. Income and property taxes are those that tax all or any part of the income or property, including taxes on profits arising from the disposal of movable or immovable property, as well as capital gains taxes.

3. The current taxes to which this Convention specifically applies are:

(a) Austria:

(i) Personal Income Tax;

(ii) Corporate tax;

(iii) Income contribution for housing promotion and compensation of family burdens;

(iv) The Administrators ' Tax;

(v) The Industrial and Commercial Exploitation Tax, including the Salary or Salary Tax;

(vi) Property Tax;

(vii) Territorial contribution;

(viii) The Farm and Forestry Tax;

(ix) Tax on the value of unbuilt land;

(x) Property tax not subject to inheritance tax (hereinafter referred to as 'Austrian tax').

(b) In Spain:

(i) The General Personal Income Tax;

(ii) The General Income Tax on Companies and Other Legal Entities, including the special charge of 4 per 100 established by article 104 of Law 41/1964 of 11 June;

(iii) The following taxes on account: The Territorial Contribution on Rustic and Pecuaria Wealth, the Territorial Contribution on Urban Wealth, the Income Tax on Personal Work, the Capital Income Tax and the Tax on Commercial and Industrial Activities and Benefits;

(iv) In Fernando Poo, Río Muni, Sahara and Ifni, income taxes (on labour and property returns) and corporate profits;

(v) The area fee, gross product tax and excise duty on profits, regulated by the Act of 26 December 1958 (applicable to undertakings engaged in the research and exploitation of hydrocarbons);

(vi) Local taxes on income or wealth (hereinafter referred to as the Spanish tax).

4. This Convention shall also apply to future taxes of an identical or similar nature which are added to or replaced by existing taxes. Each year, the competent authorities of the Contracting States shall notify each other of any changes made to their respective tax laws.

Where any amendment is made to the tax legislation of one of the Contracting States, in particular if it affects taxation on dividends or interest, the two Contracting States shall, at the request of either Contracting State, commence negotiations to review the provisions of this Convention affected by the amendment.

1. This Convention, unless otherwise interpreted:

(a) The words ‘one Contracting State’ and ‘the other Contracting State’ mean the Republic of Austria or Spain (the peninsular Spain, the Balearic Islands and the Canary Islands, the Spanish Steps and Provinces in Africa and Equatorial Guinea, formed by the territories of Río Muni and Fernando Poo, these two territories in the process of self-determination), as derived from the text;

(b) The term ‘person’ includes natural persons, corporations and any other grouping of persons;

(c) The term ‘Society’ means any legal person or any entity that is considered a legal person for tax purposes;

(d) The terms ‘Company of one Contracting State’ and ‘Company of the other Contracting State’ mean an Enterprise operated by a resident of Austria and an Enterprise operated by a resident of Spain, as per the text;

(e) ‘competent authority’ means:

1. In Austria, the Federal Ministry of Finance.

2. In Spain, the Minister of Finance, the Director-General of Direct Taxes or any other authority to which the Minister delegates.

2. For the purposes of the application of this Convention by a Contracting State, any expression not otherwise defined shall, unless the text requires a different interpretation, have the meaning attributed to it by the law of that Contracting State concerning taxes which are the subject of this Convention.

1. For the purposes of this Convention, any person who, under the law of that State, is subject to taxation in that State by reason of his domicile, residence, place of address or any other criterion of a similar nature is considered a ‘resident of a Contracting State’.

2. Where, under the provisions of paragraph 1, a natural person is resident in both Contracting States, the case shall be settled in accordance with the following rules:

(a) This person shall be considered a resident of the Contracting State where he or she has a permanent dwelling at his or her disposal. If it has a permanent dwelling at its disposal in both Contracting States, it shall be considered a resident of the Contracting State with which it maintains closer personal and economic relations (centre of vital interests);

(b) If the Contracting State in which that person has the centre of his or her vital interests cannot be determined, or if he or she does not have permanent housing at his or her disposal in any of the Contracting States, he or she shall be considered a resident of the Contracting State in which he or she normally lives;

(c) If he or she is habitually resident in either Contracting State or is not resident in either Contracting State, he or she shall be considered a resident of the Contracting State of which he or she is a national.

3. Where under the provisions of paragraph 1, a person, excluding natural persons, is a resident of both Contracting States, he or she shall be considered a resident of the Contracting State in which his or her place of effective management is located. If the place of place of effective management cannot be determined, the person concerned shall be considered a resident of the Contracting State in which he or she was incorporated.

1. For the purposes of this Agreement, the term ‘permanent establishment’ means a fixed place of business in which an Enterprise carries out all or part of its activity.

2. The term ‘permanent establishment’ includes, in particular:

(a) Management offices;

(b) Branches;

(c) Offices;

(d) Factories;

(e) Workshops

(f) Mines, quarries or any other place of extraction of natural resources;

(g) Construction or assembly works for a duration exceeding twelve months.

3. The term ‘permanent establishment’ does not include:

(a) The use of facilities for the sole purpose of storing, displaying or delivering goods or goods belonging to the Enterprise;

(b) The maintenance of a warehouse of goods or goods belonging to the Enterprise for the sole purpose of storing, displaying or delivering them;

(c) The maintenance of a warehouse of goods or goods belonging to the Enterprise for the sole purpose of their processing by another Company;

(d) The maintenance of a fixed place of business for the sole purpose of purchasing goods or goods or collecting information for the Enterprise:

(e) The maintenance of a fixed place of business for the sole purpose of advertising, providing information, conducting scientific research or carrying out other similar activities that are preparatory or auxiliary in nature, provided that these activities are carried out for the Enterprise itself.

4. A person acting in a Contracting State on behalf of an Enterprise of the other Contracting State, except in the case of an independent agent covered by paragraph 5, is considered to constitute a permanent establishment in the State first mentioned if he has and habitually exercises in that State powers to conclude contracts on behalf of the Enterprise, unless his activities are limited to the purchase of goods or goods for the Enterprise.

5. An Enterprise of one Contracting State is not considered to have a permanent establishment in the other Contracting State merely because it carries out activities in that other State through a broker, a general commissioner, or any other meter enjoying an independent status, provided that these persons act within the ordinary framework of their activity.

6. The fact that a Company resident of a Contracting State controls or is controlled by a Company resident of the other Contracting State or that it carries out activities in another State (whether by permanent establishment or otherwise) does not in itself render any of these Societies permanent establishment of the other State.

1. Income from immovable property may be taxed only in the Contracting State in which such property is situated.

2. The term ‘real property’ shall be defined in accordance with the law of the Contracting State in which the property is situated. In any event, this term includes accessories, livestock and equipment used on agricultural and forestry holdings, rights to which the provisions of private law relating to territorial property, the use of immovable property and rights to variable or fixed fees for the exploitation or concession of the exploitation of mineral deposits, sources or other land wealth apply.

3. The provisions of paragraph 1 apply to income derived from the direct use, lease or any other form of exploitation of immovable property.

4. The provisions of paragraphs 1 and 3 also apply to income derived from the immovable property of the Enterprises and from immovable property used for the exercise of professional services.

1. The profits of an Enterprise of a Contracting State may only be taxed in that State unless the Enterprise carries out operations in the other State through a permanent establishment located in that State. In the latter case, the profits of the Enterprise can only be taxed in the other State, but only to the extent that they can be attributed to the permanent establishment.

2. Where an Enterprise of one Contracting State engages in business in the other Contracting State by means of a permanent establishment situated therein, in each Contracting State the profits it would obtain from the permanent establishment if it were a separate and separate Enterprise carrying out the same or similar activities under the same or similar conditions and dealing entirely independently with the Enterprise from which it is a permanent establishment.

3. For the purpose of determining the benefit of the permanent establishment, the deduction of expenses for the purposes of the permanent establishment shall be permitted, duly demonstrated, including management and general administrative expenses for the same purposes, equally demonstrated, whether incurred in the State in which the permanent establishment is located or elsewhere.

4. As long as it is customary in a Contracting State to determine the profits attributable to permanent establishments on the basis of a distribution of the total profits of the Enterprise among its various parties, the provisions of paragraph 2 shall not prevent that Contracting State from determining the taxable profits in this way; however, the method of distribution adopted shall be such that the result obtained is in accordance with the principles set out in this Article.

5. For the purposes of the preceding paragraphs, the profits attributable to the permanent establishment shall be calculated each year by the same method, unless there are valid and sufficient grounds for otherwise proceeding.

6. Where profits comprise income separately regulated in other articles of this Convention, the provisions of those articles shall not be affected by those of this Article,

7. The provisions of paragraphs 1 to 8 shall also apply to income earned by an account holder in an Austrian joint venture account.

1. Profits from operating ships or aircraft in international traffic may be taxed only in the Contracting State in which the effective head office of the Enterprise is located.

2. The profits from the operation of vessels engaged in inland waterway transport may be taxed only in the Contracting State in which the effective head office of the Enterprise is situated.

3. If the seat of effective management of a Navigational Enterprise or of an Undertaking engaged in inland waterway transport is on board a ship or vessel, it shall be deemed to be in the Contracting State where the base port of the ship or vessel is located and, if there is no such base port, in the Contracting State in which the person operating the vessel or vessel resides.

When

(a) A person of a Contracting State participates, directly or indirectly, in the direction, control or capital of an Enterprise of the other Contracting State; or

(b) The same persons participate, directly or indirectly, in the direction, control or capital of an Enterprise of one Contracting State and an Enterprise of the other Contracting State,

And, in either case, the two Companies are, in their commercial or financial relations, bound by terms, accepted or imposed, which differ from those that would be agreed by independent Companies, the profits that one of the Companies would have obtained in the absence of these conditions and which in fact did not occur because of them, may be included in the profits of this Company and subject to taxation accordingly.

1. Dividends paid by a Company resident of a Contracting State to a resident of the other Contracting State may be taxed in the latter State.

2. However, such dividends may be taxed in the Contracting State in which the company that pays the dividends resides and in accordance with the laws of that State, but the tax thus required may not exceed:

(a) Ten per cent of the gross amount of dividends, if the beneficiary in a company (excluding the Companies of persons) owns directly at least 50 per cent of the capital of the company that pays them, provided that this participation is represented by shares held at least one year prior to the date of distribution.

(b) Fifteen per cent of the gross amount of dividends in all other cases.

The competent authorities of the Contracting States shall, by mutual agreement, determine how these limits are to be applied.

This paragraph does not affect the Company's taxation of profits against which dividends are paid.

3. The term ‘dividends’, used in this Article, covers the income from shares, shares or vouchers, parts of mines, shares of founders or other rights, except credit rights, which permit participation in the profits, as well as income from other social participations assimilated to the income of the shares by the tax legislation of the State in which the distribution company resides.

4. The provisions of paragraphs 1 and 2 do not apply if the dividend beneficiary, resident of one Contracting State, has in the other Contracting State of which the corporation paying the dividends is resident, a permanent establishment with which the dividend holding is effectively linked. In this case, the provisions of article 7 apply.

5. Where a Company resident of one Contracting State obtains profits or income from the other Contracting State, that other State may not require any tax on dividends paid by the Company to persons who are not residents of the latter State, or subject the profits not distributed by the Company to a tax on them, even if the dividends paid or profits not distributed consist, in whole or in part, of profits or income from that other State.

1. Without prejudice to the provisions of paragraph 3, interest from a Contracting State paid to a resident of the other Contracting State may be taxed in the latter State.

2. However, these interests may be taxed in the Contracting State from which they come and in accordance with the law of that State, but the tax thus required may not exceed 5 per 100 of the amount of interest. The competent authorities of the Contracting States shall, by mutual agreement, determine how this limit is to be applied.

3. The interests of the public debt of a Contracting State may only be subject to taxation in that State.

4. The term ‘interest’, used in this article, includes the income from the public debt, from bonds or bonds, with or without mortgage guarantee and entitled or not to participate in profit, and from credits of any kind, as well as any other income that the tax laws of the State from which the interest originates assimilate to the returns the amounts given to the loan.

5. The provisions of paragraphs 1, 2 and 3 do not apply if the beneficiary of the interest, resident of one Contracting State, has in the other Contracting State from which the interest originates, a permanent establishment with which the claim generating the interest is effectively linked. In this case, the provisions of article 7 apply.

6. Interests are considered to come from a Contracting State where the debtor is the State itself, one of its political or administrative subdivisions, one of its authorities, local authorities or a resident thereof. However, where the debtor of interest, whether resident or not of a Contracting State, has in a Contracting State a permanent establishment in respect of which the debt giving rise to the interest has been incurred, and this establishment supports the payment thereof, interest shall be deemed to have come from the Contracting State in which the permanent establishment is located.

7. Where, due to special relationships between the debtor and the beneficiary of the interest or between the two and any other person, the amount of interest paid, taking into account the claim for which it is paid, exceeds the amount that would have been agreed upon by the debtor and benefit it in the absence of such relations, the provisions of this article shall apply only to the latter amount. In this case, the excess may be imposed in accordance with the law of each Contracting State, taking into account the other provisions of this Convention.

1. Fees from one Contracting State paid to a resident of the other Contracting State may be taxed in the latter State.

2. However, these fees may be taxed in the Contracting State from which they come and in accordance with the law of that State, but the tax thus required may not exceed 5 per 100 of the gross amount of the fees.

3. The term ‘royalties’ used in this article includes amounts of any kind paid for the use or granting of copyright on literary, artistic or scientific works, including cinematographic, patent, trademark, designs, plans, formulas or secret procedures, as well as for the use or granting of use of industrial, commercial or scientific equipment, and amounts paid for information relating to industrial, commercial or scientific experience.

4. The provisions of paragraphs 1 and 2 do not apply if the beneficiary of the royalties, resident of one Contracting State, has in the other Contracting State, from which the royalties come, a permanent establishment with which the right or ownership for which the royalties are paid is effectively linked. In this case, the provisions of article 7 apply.

5. The fees are deemed to come from a Contracting State where the debtor is the State itself, one of its political subdivisions, or one of its local authorities or a resident thereof. However, where the debtor of the royalties, whether or not he is resident of a Contracting State, has in a Contracting State a permanent establishment in respect of which the obligation to pay the royalties has been entered into and this establishment supports the payment of the royalties, the fees shall be deemed to come from the Contracting State where the permanent establishment is located.

6. Where due to special relations between the debtor and the beneficiary of the royalties or between them and any other person, the amount of the fees paid, taking into account the use, right or information for which they are paid, exceeds the amount that would have been agreed by the debtor and the beneficiary in the absence of such relationships, the provisions of this Article shall apply only to the latter amount. In this case, the excess may be imposed in accordance with the law of each Contracting State, taking into account the other provisions of this Convention.

1. Profits arising from the disposal of immovable property, as defined in article 6, paragraph 2, may be taxed only in the Contracting State in which they are located.

2. Gains arising from the disposal of movable property forming part of the assets of a permanent establishment held by an Enterprise of one Contracting State in the other Contracting State, or from movable property belonging to a fixed base held by a resident of one Contracting State in the other Contracting State for the provision of professional services, including gains arising from the disposal of the permanent establishment (either alone or with the enterprise as a whole) or from the fixed base, may only be taxed in that other State. However, the proceeds from the disposal of movable property referred to in article 23, paragraph 3, may be taxed only in the Contracting State to which, under that article, the right to tax them belongs.

3. Profits arising from the disposal of any property other than those referred to in paragraphs 1 and 2 may be taxed only in the State in which the transferor resides.

1. Income obtained by a resident of a Contracting State through the provision of professional services or the pursuit of other independent activities of a similar nature may only be taxed in that State unless that resident normally has a fixed basis in the other Contracting State for the pursuit of his activity. In the latter case, such income may be taxed only in the other State, but only to the extent that it is appropriate to attribute it to the fixed base.

2. The term “professional services” includes, in particular, scientific, literary, artistic, educational or educational activities, as well as independent activities of doctors, lawyers, engineers, architects and accountants.

The provisions of article 7 apply to income obtained by a resident of one Contracting State in the other Contracting State as a broker, general commissioner or mediator of any kind enjoying an independent status.

1. Without prejudice to the provisions of Articles 19 and 20, salaries, salaries and similar remuneration obtained by a resident of a Contracting State on the basis of employment may only be taxed in that State unless the employment is exercised in the other Contracting State. If employment is exercised in the latter State, the remuneration derived from it may only be subject to taxation in that State.

2. Notwithstanding the provisions of paragraph 1, remuneration obtained by a resident of a Contracting State on the ground of employment in the other Contracting State may only be taxed in the former State if:

(a) The employee does not remain in total in the other State, for one or more periods, more than one hundred and eighty-three days during the fiscal year concerned; and

(b) Remuneration is paid by or on behalf of a person who is not a resident of the other State; and

(c) Remuneration is not borne by a permanent establishment or a fixed basis which the person for whom work is performed has in the other State.

3. However, the preceding provisions of this Article, remuneration obtained on account of employment carried out on board a ship or aircraft in international traffic or a vessel intended for inland waterway transport, may be subject to taxation only in the Contracting State in which the place of effective management of the Company is located.

Participations, attendance allowances and similar remunerations which a resident of a Contracting State obtains as a member of a Board of Directors or a Supervisory Board of a Company resident of the other Contracting State may be subject to taxation only in that other State.

Notwithstanding the provisions of Articles 14 and 16, the rents earned by entertainment professionals, such as theatre, cinema, radio or television artists and musicians, as well as by sportsmen, for their personal activities in this regard, may be subject to taxation only in the Contracting State in which they act,

Without prejudice to the provisions of article 20, paragraph 1, pensions and similar remuneration paid, in consideration of previous employment, to a resident of a Contracting State, may only be taxed in that State.

1. Remuneration, including pensions, paid by or from funds created by a Contracting State, one of its political or administrative subdivisions, one of its local authorities or a Corporation governed by public law of that State to a natural person in consideration for services previously provided to them in the exercise of functions of a public nature, may be subject to taxation only in that State.

2. The provisions of Articles 16, 17 and 19 apply to remuneration and pensions paid for services rendered in connection with commercial or industrial activities carried out by a Contracting State, one of its political or administrative subdivisions, one of its local authorities or a Corporation governed by public law.

1. The amounts that a student or a trainees, who is or has previously been a resident of a Contracting State and who is in the other Contracting State for the sole purpose of continuing his studies or completing his training, shall not be subject to taxation in the latter State, provided that such amounts come from sources outside that State.

2. Remunerations which a student or a trainees, who is or has previously been a resident of a Contracting State, obtains from employment in the other Contracting State, for the purpose of exercising, for a period or periods not exceeding a total of one hundred and eighty-three days in the year concerned, may not be subject to taxation in the latter State.

The income of a resident of a Contracting State not expressly mentioned in the preceding articles may only be taxed in that State.

1. Property constituted by immovable property, as defined in article 6, paragraph 2, may be taxed only in the Contracting State in which the property is situated.

2. Property consisting of movable property forming part of the assets of a permanent establishment of an Enterprise, or of movable property belonging to a fixed base used for the pursuit of a professional activity, may be taxed only in the Contracting State in which the permanent establishment or fixed base is situated.

3. Vessels and aircraft operated in international traffic and vessels engaged in inland waterway transport, as well as movable property affected by their operation, may be subject to taxation only in the Contracting State in which the effective headquarters of the Enterprise is located.

4. All other assets of a resident of a Contracting State may be subject to taxation only in that State.

1. Where a resident of a Contracting State obtains income or possesses property which, in accordance with the provisions of this Convention, can only be taxed in the other Contracting State, the first State, except as provided for in the following paragraph, shall exempt such income or property, but in order to calculate the tax corresponding to the remaining income or property of that person, may apply the tax rate which would correspond without such exemption.

2. Where a resident of a Contracting State obtains income which, in accordance with the provisions of Article 10, paragraph 2, Article 11, paragraph 2, and Article 12, paragraph 2, may be taxed in the other Contracting State, the first State shall deduct from the income tax of that person an amount equal to the tax paid in the other Contracting State. However, this deduction may not exceed the part of the tax, calculated before the deduction, corresponding to the income obtained in the other Contracting State.

3. In Spain the tax paid in Austria will also be deducted from the account tax, in accordance with the provisions of paragraph two above.

Where the Spanish tax on account is required before the Austrian taxes which, in accordance with this Agreement, are deductible from them, and the quotas of the Spanish general taxes do not allow the deduction of the corresponding amount under this paragraph and the preceding, the excess shall be refunded.

1. Nationals of a Contracting State shall not be subject in the other Contracting State to any taxes or obligations relating thereto which are not or are more burdensome than those to which nationals of that latter State who are or may be subject under the same conditions.

2. The term ‘national’ means:

(a) All natural persons possessing the nationality of a Contracting State.

(b) All legal persons, companies of persons and associations whose status as such derives from the laws in force in a Contracting State.

3. A permanent establishment which an Enterprise of one Contracting State has in the other Contracting State shall not be subject to taxation in that State in a less favourable manner than the Enterprises of the latter State carrying out the same activities.

This provision does not oblige a Contracting State to grant to residents of the other Contracting State the personal deductions, reliefs and tax reductions it grants to its own residents in view of their marital status or family burdens.

4. Undertakings of a Contracting State whose capital is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State shall not be subject in the Contracting State referred to above to any tax or obligation relating thereto which is not or is more burdensome than those to which similar undertakings of the former State are or may be subject.

1. Where a resident of a Contracting State considers that the measures taken by one or both Contracting States imply or may represent for him a charge that is not in conformity with this Convention, irrespective of the remedies provided for by the national law of the States, he may submit his case to the competent authority of the Contracting State of which he is a resident.

2. This competent authority shall, if it finds the complaint well founded and if it is not in a position to adopt a satisfactory solution, make every effort to resolve the matter through an amicable agreement with the competent authority of the other Contracting State in order to avoid the imposition which does not comply with this Convention.

3. The competent authorities of the Contracting States shall endeavour to resolve, by amicable agreement, difficulties or to dispel doubts arising from the interpretation or application of this Convention. They may also agree to try to avoid double taxation in cases not provided for therein.

4. The competent authorities of the Contracting States may communicate directly with each other in order to achieve the agreements referred to in the preceding paragraphs. Where it is considered that such agreements may be facilitated by personal contracts, the exchange of views may take place within a committee composed of representatives of the competent authorities of both Contracting States.

1. The competent authorities of the Contracting States shall exchange the information necessary for the application of this Convention and of the domestic laws of the Contracting States relating to taxes covered by this Convention which are required in accordance with it. The information thus exchanged shall be kept secret and shall not be disclosed to any person or authority which is not responsible for the settlement or collection of the taxes covered by this Agreement,

2. Under no circumstances does the provisions of paragraph 1 oblige a Contracting State:

(a) To take administrative measures contrary to its legislation or administrative practice or those of the other Contracting State.

(b) Provide information that cannot be obtained on the basis of their own legislation or normal administrative practice or that of the other Contracting State.

(c) To transmit information revealing a commercial, industrial, business or professional secret, or a commercial or industrial procedure, or information whose communication is contrary to public policy.

The provisions of this Convention do not affect the tax privileges enjoyed by diplomatic or consular officials in accordance with the general principles of international law or under special agreements.

1. This Convention shall be ratified and the instruments of ratification shall be exchanged in Madrid as soon as possible.

2. This Convention shall enter into force on 1 January of the year following the year in which the instruments of ratification have been exchanged, and its provisions shall take effect from that date.

3. Article 8 and paragraph 3 of article 23 shall apply, notwithstanding the provisions of paragraph 2, from 1 January 1965.

This Convention shall remain in force until it is denounced by one of the Contracting States. Any of them may report it through diplomatic channels, at least six months before the end of each calendar year. In such a case, the Convention shall cease to have effect on taxes incurred in the calendar years following the year in which the denunciation is made.

In faith, the undersigned, duly authorized, sign and seal this Convention.

Done at Vienna on 20 December 1966, in duplicate, in both Spanish and German languages, both of which have faith.

Therefore, having seen and examined the thirty articles that make up the said Convention, having heard the Commission of Treaties of the Spanish Courts, in compliance with article 14 of its Organic Law, I come to approve and ratify what is provided for, as I hereby approve and ratify it, promising to comply with it, observe it and ensure that it is implemented and observed in a timely manner in all its parts, for the purpose of its further validation and firmness, Command to issue this instrument of ratification signed by Me, duly sealed and endorsed by the undersigned Minister of Foreign Affairs.

[ignore]Dated in San Sebastián to fourteen September of one thousand nine hundred and sixty-seven.

FRANCE FRANCE

The Minister for Foreign Affairs,

FERNANDO MARY CASTIELLA AND MAÍZ

The Exchange of Instruments of Ratification took place in Madrid on 8 November 1967 and will enter into force on 1 January 1968, in accordance with its article 29.