Finland

FRANCIS FRANCH BAHAMONDE

HEAD OF SPANISH STATE

GENERALIZATION OF NATIONAL AFFAIRS

For what? on 18 and 24 August 1970, the Plenipotentiaries of Spain and Finland proceeded in San Sebastián to the Exchange of Letters adding a fourth paragraph to article 23 of the Convention between Spain and the Republic of Finland on the Prevention of Double Taxation on Income and on Heritage, signed at Helsinki on 15 November 1967; having regard to and examined that additional paragraph, having heard the Commission on Foreign Affairs of the Spanish Courts, pursuant to article 14 of its constituent law,

I'm coming to approve and ratify what is provided for, as I hereby approve and ratify it, by promising to comply with it, observe it and ensure that it is complied with and observed in a timely manner in all its parts, for the purpose of which, for its further validation and firmness, I command to issue this Instrument of Ratification, signed by Me, duly sealed and endorsed by the undersigned Minister for Foreign Affairs.

Given in Madrid on January 7, 1974.

FRANCE FRANCE

The Minister for Foreign Affairs,

LAUREANO LÓPEZ RODO

San Sebastian, August 21, 1970.

[precept] Mr. Ambassador:

I have the honour to refer to your note dated 18 of this month, which reads as follows:

'I have the honour to refer to the Convention between the Republic of Finland and Spain on the Prevention of Double Taxation of Income and Wealth Taxes, signed on 15 November 1967, and to propose the establishment of a Convention between Finland and Spain adding a fourth paragraph to Article 23 of that Convention, the content of which would be as follows:

Notwithstanding paragraph 2 of this article, dividends paid by a company resident in Spain to a company resident in Finland shall be exempt from Finnish tax to the extent and under the conditions under which such relief would be granted under Finland's domestic law in the event that both companies were resident in Finland.

In the event that this proposal can be accepted by Spain, I also have the honour to propose that this letter and its reply form the Convention between Finland and Spain on this subject, which will enter into force on the thirtieth day after the Governments of the Contracting States have notified each other that they have fulfilled the constitutional preconditions necessary for its entry into force and that it will apply for the first time to the imposition which will take place in the year of its entry into force.'

I have the honour to express to you the Spanish Government's agreement with the foregoing.

Please accept, Mr. Ambassador, the assurances of my high consideration.

GREGORIO LOPEZ BRAVO

H.E. Sir. Juha Montonen.

Ambassador Extraordinary and Plenipotentiary of Finland.

San Sebastian,

This Exchange of Letters shall enter into force on 11 February 1974.

What is made public for your general knowledge.

[ignore]Madrid, January 24, 1974.—The Technical Secretary General of the Ministry of Foreign Affairs. Enrique Thomas de Carranza.