Bulgaria

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

2. For the purposes of this Convention, the following are considered residents:

(a) In the case of Bulgaria, natural persons who are nationals of the People's Republic of Bulgaria and legal persons who have their head office in Bulgaria or who are registered there.

(b) In the case of Spain, persons who are subject to taxation under Spanish law in Spain by reason of their domicile, residence, address or any other criterion of a similar nature.

3. Where, under the provisions of paragraph 2, a natural person is resident in both Contracting States, he or she shall be considered a resident of the State with which he or she has closer personal and economic relations (centre of vital interests).

4. If the State in which that person has the centre of his vital interests cannot be determined, the competent authorities of the Contracting States shall settle the case by amicable agreement.

5. Where under the provisions of paragraph 2, a person other than a natural person is a resident of both Contracting States, he or she shall be considered a resident of the State in which his or her place of effective management is located.

1. This Convention applies to income and property taxes payable by each of the Contracting States.

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

(a) In Spain:

(i) Personal Income Tax;

(ii) Corporate tax;

(iii) Property Tax; and

(iv) Local income and property taxes.

(hereinafter referred to as ‘the Spanish tax’).

(b) Bulgaria:

(i) Total income tax;

(ii) Income Tax for single persons, widows, divorced persons and spouses without children;

(iii) Profit Tax; and

(iv) Building Tax.

(hereinafter referred to as ‘the Bulgarian tax’).

3. This Convention shall also apply to taxes of an identical or similar nature which are established after the date of signature of this Convention and which are added to or replaced by current taxes. The competent authorities of the Contracting States shall notify each other of any relevant amendments to their respective tax laws. If the competent authorities of the two Contracting States disagree on the application of the first sentence of this paragraph, discussions will begin on whether to amend the Convention for the inclusion of the new tax in question.

1. For the purposes of this Convention, unless the context of the Convention is different:

(a) The term ‘Spain’ means the territory of the Spanish State, including any area outside its territorial sea in which the Spanish State, under international law and under its domestic law, exercises or may exercise in the future sovereign jurisdiction or rights.

(b) The term ‘Bulgaria’ means the territory of the People's Republic of Bulgaria to which the sovereignty of the State extends, as well as the continental shelf over which the People's Republic of Bulgaria exercises sovereign rights under international law.

(c) The terms ‘one Contracting State’ and ‘the other Contracting State’ mean Spain or Bulgaria, depending on the context.

(d) The term ‘person’ includes natural persons, groups of persons, legal persons, including Companies, and any Entity that is considered a legal person for tax purposes.

(e) The terms ‘Company of one Contracting State’ and ‘Company of the other Contracting State’ mean, respectively, an Enterprise operated by a resident of a Contracting State and an Enterprise operated by a resident of the other Contracting State.

(f) “International traffic” means any transport carried out by a ship, aircraft or road transport vehicle operated by an Enterprise whose place of effective management is located in a Contracting State, except where the ship, aircraft or road transport vehicle is operated only between points situated in the other Contracting State.

(g) ‘competent authority’ means:

(i) In the case of Spain, the Minister of Economy and Finance or any other authority to which the Minister delegates.

(ii) In the case of Bulgaria, the Minister of Finance or his authorized representative.

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

1. For the purposes of this Convention, the term ‘permanent establishment’ means a fixed place where a resident of a Contracting State carries out all or part of his business activity in the other Contracting State.

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

(a) Management offices.

(b) Branches.

(c) Offices.

(d) Factories.

(e) Workshops.

(f) Mines, oil or gas wells, quarries or any other natural resource extraction site.

3. Construction, installation or assembly works constitute a permanent establishment only if their duration exceeds 12 months.

4. The participation of a resident in Spain in a joint venture, constituted in accordance with Bulgarian law, shall be regarded as a permanent establishment situated in the People's Republic of Bulgaria.

5. Notwithstanding the preceding provisions of this Article, it is considered that 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 exhibited by the Company at a trade fair or exhibition intended for sale at its closure.

(d) The maintenance of a deposit of goods or goods belonging to the Enterprise for the sole purpose of their processing by another Company.

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

(f) The maintenance of a fixed place of business for the sole purpose of carrying out, for the enterprise, any other activity of an auxiliary or preparatory nature.

(g) The maintenance of a fixed place of business for the sole purpose of the combined exercise of the activities referred to in subparagraphs (a) to (f), provided that the activity of the fixed place of business as a whole retains its auxiliary or preparatory character.

6. By way of derogation from paragraphs 1 and 2, where a person, other than an agent enjoying an independent status to whom paragraph 7 applies, acts on behalf of an undertaking and habitually exercises in a contracting State powers to conclude contracts on behalf of the undertaking, that undertaking shall be deemed to have a permanent establishment in that State in respect of all activities carried out by that person on behalf of the undertaking, unless the activities of that person are limited to those referred to in paragraph 5 which, if carried out through a fixed place of business, have not determined that such place of business should be regarded as a permanent establishment in accordance with the provisions of that paragraph.

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

8. The fact that a company resident of a Contracting State participates in a company of the other Contracting State, or engages in activities in that other State (whether by permanent establishment or otherwise), does not in itself make any of the companies a permanent establishment of the other State.

1. The income that a resident of one Contracting State obtains from immovable property situated in the other Contracting State may be taxed in that other State.

2. The term ‘real property’ shall have the meaning attributed to it by the law of the Contracting State in which the goods in question are situated.

1. The profits of an Enterprise of a Contracting State may be taxed only by that State, unless the Enterprise carries out its business in the other Contracting State through a permanent establishment situated therein. If the Enterprise does so, the profits of the Enterprise may be taxed in the other State, but only to the extent that they can be attributed to that permanent establishment.

2. Without prejudice to the provisions of paragraph 3, where an Enterprise of one Contracting State carries out its activity in the other Contracting State by means of a permanent establishment situated therein, in each Contracting State the profits which it would have obtained from being 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 shall be attributed to that establishment.

3. The determination of the benefits of the permanent establishment shall allow the deduction of the expenses incurred for the realization of the purposes of the permanent establishment, including management expenses and general administration expenses for the same purposes, whether incurred in the State in which the permanent establishment is located or elsewhere.

4. Benefits shall not be attributed to a permanent establishment merely because it purchases goods or goods for the Enterprise.

5. Where profits include regular income separately in other articles of this Convention, the provisions of those articles shall not be affected by those of this Article.

1. The profits from operating ships, aircraft or road transport vehicles in international traffic may be taxed only in the Contracting State in which the effective head office of the Enterprise is located.

2. If the place of effective management of a Navigational Enterprise is on board a ship, it shall be deemed to be in the Contracting State where the base port of the ship is located, and if there is no such base port, in the Contracting State of which the person operating the ship is resident.

3. The provisions of paragraph 1 also apply to the benefits of participation in a pool, on a joint holding or in an international holding body.

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

2. However, such dividends may also be subject to taxation in the Contracting State of which the dividend paying company is resident and in accordance with the law of that State, but if the dividend receiving company is its beneficial owner, the tax thus required may not exceed:

(a) 5 per cent of the gross amount of dividends if the beneficial owner is a company, excluding the Companies of Persons (Partnerships), which owns directly or indirectly at least 25 per cent of the company's capital that pays the dividends;

(b) 15 per cent of the gross amount of dividends in other cases.

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

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

3. The term ‘dividends’ used in this Article means the income from shares, as well as the income from other social shares subject to the same tax regime as the income from shares under the law of the State of which the distribution company is resident.

4. The provisions of paragraphs 1 and 2 do not apply if the beneficial owner of the dividends resident in one Contracting State, in the other Contracting State, from which the Company paying the dividends is resident, is an industrial or commercial activity through a permanent establishment located in that other State or provides independent personal services through a fixed base situated therein, and to which the share generated by the dividends is effectively linked. In such a case, the provisions of article 6 or article 12, as appropriate, apply.

5. Where a Company resident of a Contracting State obtains profits or income from another Contracting State, that other State may not require any tax on dividends paid by the Company, except to the extent that such dividends are paid to a resident of that other State, or the share generated by the dividends is effectively linked to a permanent establishment or a fixed base situated in that other State, or subject the undistributed profits of the Society to a tax on them, even if dividends paid or undistributed profits consist, in whole or in part, of profits or income from that other State.

1. Interest from one Contracting State and paid to a resident of the other Contracting State may be taxed only in that other State.

2. The term ‘interest’ used in this Article means income from claims of any kind, with or without a mortgage guarantee or a benefit-sharing clause of the debtor, and in particular income from public funds and bonds or bonds, including premiums and lots attached to such securities. Penalties for late payment are not considered interest for the purposes of this article.

3. The provisions of paragraph 1 shall not apply if the beneficial owner of the interest, resident of a Contracting State, performs in the other Contracting State, from which the interest is derived, an industrial or commercial activity through a permanent establishment situated in that other State or provides independent personal services through a fixed base situated therein, and the credit generated by the interest is effectively linked to that permanent establishment or fixed base. In such a case, the provisions of article 6 or article 12, as appropriate, apply.

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

2. The term ‘royalties’ used in this Article means the quantities of any kind received for the use, or right to use, of copyright, patents, trademarks, designs, formulas or secret procedures, as well as for the use, or right to use, of industrial, commercial or scientific equipment and information relating to industrial, commercial or scientific experiences, and includes quantities of any kind paid for by film and video films or tapes for use in connection with television.

3. The provisions of paragraph 1 do not apply if the beneficial owner of the royalties, resident in a Contracting State, carries out in the other Contracting State from which the royalties come an industrial or commercial activity by means of a permanent establishment situated in that other Contracting State or provides independent personal services through a fixed base situated therein, and the right or for which the royalties are paid is effectively linked to that permanent establishment or fixed base. In such a case, the provisions of article 6 or article 12, as appropriate, apply.

1. Profits that a resident of one Contracting State obtains from the disposal of immovable property, as defined in Article 5, located in the other Contracting State, may be taxed in that other State.

2. Gains 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 having a fixed basis that a resident of one Contracting State has in the other Contracting State for the provision of independent personal services, including gains from the disposal of such permanent establishment (only or with the enterprise as a whole) or from that fixed basis, may be taxed in that other State.

3. Profits resulting from the disposal of ships, aircraft or road transport vehicles operated in international traffic, or from movable property affected by the operation of such ships, aircraft or road transport vehicles, may only be taxed in the Contracting State where the effective head office of the Enterprise is located.

4. Profits resulting from the disposal of any goods other than those referred to in paragraphs 1, 2 and 3 may be taxed only in the Contracting State of which the transferor is resident.

1. Revenues obtained by a resident of a Contracting State from the provision of professional services and other activities of an independent nature may only be taxed in that State unless such resident normally has a fixed basis for carrying out his or her activities in the other Contracting State.

If it has such a fixed base, income may be taxed in that other State, but only to the extent that it can be attributed to that fixed base.

2. The term “professional services” includes, in particular, independent scientific, literary, artistic, educational or pedagogical activities, as well as independent activities of Physicians, Lawyers, Engineers, Architects, Dentistry and Accountants.

1. Without prejudice to the provisions of articles 14, 16 and 17, salaries, wages and similar remuneration obtained by a resident of a Contracting State on account of employment may be subject to taxation only in that State, unless the employment is exercised in the other Contracting State. If the employment is exercised there, the remuneration received for this purpose may be subject to taxation in that other State.

2. Notwithstanding the provisions of paragraph 1, remunerations obtained by a resident of a Contracting State on the basis of employment in the other Contracting State may be taxed only in the State referred to above if:

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

(b) Remuneration is paid by, or on behalf of, an employer 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 employer has in the other State.

3. Notwithstanding the foregoing provisions of this Article, remunerations obtained on account of employment on board a ship, aircraft or road transport vehicle operated in international traffic may be taxed in the Contracting State in which the effective head office of the Enterprise is situated.

4. Notwithstanding the foregoing provisions of this Article, remunerations obtained by a resident of a Contracting State on the basis of employment in the other Contracting State may be subject to taxation in the State referred to first in the first three years of employment in that other State only if:

(a) Employment is exercised in a representation that is not commercial or industrial in nature;

(b) Remuneration is paid by an employer resident of the above-mentioned State; and

(c) Remuneration is not borne by a permanent establishment held by the employer in that other State.

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

1. Notwithstanding the provisions of Articles 12 and 13, any income which a resident of a Contracting State obtains from the exercise of his personal activity in the other Contracting State, as a performing artist, theatre, cinema, radio or television actor or musician, or as an athlete, may be subject to taxation in that other State.

2. Where the income obtained from personal activities carried out by an artist or athlete as such is attributed not to the artist or athlete himself, but to another person, such income may, notwithstanding the provisions of Articles 6, 12 and 13, be subject to taxation in the Contracting State in which the activities of the artist or athlete are carried out.

3. Income obtained by artists or sportsmen resident in a Contracting State on account of their activities in the other Contracting State as a result of cultural exchanges carried out within the framework of cultural agreements signed by the two Contracting States or of intergovernmental cooperation programmes in cultural or sporting matters may be taxed only in the Contracting State mentioned above.

Without prejudice to the provisions of Article 17(2), pensions and other similar remuneration paid to a resident of a Contracting State on account of previous employment may only be taxed in that State.

1. (a) Remuneration, with the exception of pensions, paid by a Contracting State or one of its political subdivisions or local entities to a natural person, for the purpose of services rendered to that State or to that subdivision or entity, may be subject to taxation only in that State.

(b) Such remuneration may, however, be subject to taxation in the other Contracting State only if the services are provided in that State and the natural person is a resident of that State who:

(i) possesses the nationality of that State; or

(ii) It has not acquired the resident status of that State only for the provision of services.

2. (a) Pensions paid by a Contracting State or one of its political subdivisions or local entities, either directly or from constituted funds, to a natural person on account of services rendered to that State or to that subdivision or entity may be subject to taxation in that State only.

(b) However, such pensions may be subject to taxation in the other Contracting State only if the natural person is a resident and national of that other State.

3. The provisions of Articles 13, 14 and 16 apply to remuneration and pensions paid for services rendered in the context of an industrial or commercial activity carried out by a Contracting State or one of its political subdivisions or local entities.

1. Education professionals who visit a Contracting State for a period not exceeding two years, for the purpose of teaching or conducting research at a University or other officially recognized educational institution of that Contracting State and who are residents of the other Contracting State, shall be exempt from taxation in the Contracting State referred to above in respect of the remuneration of such education or research.

This paragraph shall not apply to income derived from research where it is not in the public interest, but primarily for the private benefit of a particular person or persons.

2. The amounts received to cover their costs of maintenance, study or practical training, a student or a person in practice who visits a Contracting State for the sole purpose of conducting studies or acquiring practical training and who is a resident of the other Contracting State, may not be taxed in the State referred to in the first instance, provided that such payments come from sources outside that State.

The income of a resident of a Contracting State, whatever its source, not mentioned in the previous articles of this Convention, may be taxed only in that State.

1. Property constituted by immovable property as defined in Article 5, belonging to a resident of one Contracting State and situated in the other Contracting State, may be taxed in that other State.

2. Property consisting of movable property forming part of the assets of a permanent establishment which an Enterprise of one Contracting State has in the other Contracting State, or of movable property having a fixed basis that a resident of one Contracting State has in the other Contracting State for the provision of professional services, may be taxed in the Contracting State in which the permanent establishment or the fixed base is situated.

3. Assets consisting of ships, aircraft or road transport vehicles operated in international traffic, as well as movable property affected by the operation of such vessels, aircraft or road transport vehicles, may be subject to taxation only in the Contracting State in which the effective head office of the Enterprise is situated.

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

1. In Spain double taxation will be avoided as follows:

(a) Where a resident of Spain obtains income or possesses assets which, in accordance with the provisions of this Convention, may be taxed in Bulgaria, Spain shall permit:

(i) The deduction of the income tax of that resident from an amount equal to the tax paid in Bulgaria.

(ii) The deduction of the property tax of that resident from an amount equal to the property tax paid in Bulgaria.

However, in either case, such deduction may not exceed the part of the Income or Property Tax calculated before making the corresponding deduction, as the case may be, to the income or assets which may be taxed in Bulgaria.

(b) Where, in accordance with any provision of the Convention, the income obtained by a resident of Spain or the assets he possesses are exempt from taxation in Spain, Spain may, however, take into account the income or assets exempted for the purpose of calculating the amount of the tax on the rest of the income or assets of that resident.

2. In Bulgaria, double taxation will be avoided as follows:

(a) Where a resident of Bulgaria obtains income or possesses assets which, in accordance with the provisions of this Convention, may be taxed in Spain, Bulgaria shall exempt such income or property from taxation.

(b) However, the exempt income or wealth may be taken into account for the purposes of calculating the amount of the tax on the rest of the income or assets of that resident.

(c) Notwithstanding the provisions of subparagraphs (a) and (b), where a resident of Bulgaria obtains dividends which, in accordance with the provisions of Article 8, may be taxed in Spain, Bulgaria shall allow an amount equivalent to the tax paid in Spain to be deducted from the income tax of that resident. However, this deduction may not exceed the part of the tax, calculated before deduction, corresponding to the income obtained in Spain.

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 onerous than those to which nationals of that other State who are under the same conditions are or may be subject. Notwithstanding the provisions of article 1, this provision shall also apply to nationals of any of the Contracting States who are not residents of any of them. This paragraph shall also apply to legal persons or other entities which derive their status as such from the legislation in force in a Contracting State.

2. Permanent establishments held by an Enterprise of one Contracting State in the other Contracting State shall not be subject to taxation in that State in a less favourable manner than undertakings of that other State carrying out the same activities. This provision may not be interpreted as obliging 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 consideration of their civil state or family burdens.

3. Undertakings of a Contracting State in which one or more residents of the other Contracting State participate shall not be subject in the State referred to above to any taxes or obligations relating thereto which are not or are more onerous than those to which other similar undertakings of the State referred to above are or may be subject.

4. Interest, royalties and other expenses paid by an Enterprise of one Contracting State to a resident of the other Contracting State shall be deductible, in order to determine the profits subject to taxation of that undertaking, under the same conditions as if they had been paid to a resident of the State referred to in the first instance. Similarly, the debts of an enterprise of one Contracting State to a resident of the other Contracting State shall be deductible for the determination of the assets subject to taxation of that Company under the same conditions as if they had been contracted with a resident of the State referred to in the first instance.

5. Notwithstanding the provisions of Article 2, the provisions of this Article are subject to all taxes irrespective of their nature or name.

1. Where a resident of a Contracting State considers that the measures taken by one or both Contracting States imply or may entail for him an imposition that is not in conformity with the provisions of this Convention, irrespective of the remedies provided for by the domestic law of those States, he may submit his case to the competent authority of the Contracting State of which he is resident, or, if Article 22 (1) applies, to that of the Contracting State of which he is a national. The case shall be brought within three years of the first notification of the measure involving an imposition not in accordance with the provisions of this Convention.

2. The competent authority, if it considers the complaint well founded, and if it is not in a position to adopt a satisfactory solution, shall endeavour to resolve the matter by amicable agreement with the competent authority of the other Contracting State, in order to avoid a position not in conformity with the Convention.

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

4. The competent authorities of the Contracting States may communicate directly with each other in order to reach agreement on the terms of the preceding paragraphs. Where it is considered that this agreement may be facilitated by personal contacts, the exchange of views may take place within a committee composed of representatives of the competent authorities of the Contracting States.

1. The competent authorities of the Contracting States shall exchange the information necessary to implement the provisions of this Convention or of the domestic law of the Contracting States relating to taxes covered by the Convention, to the extent that the taxation required under that Convention is not contrary to the Convention. The exchange of information is not limited by Article 1. Information received by a Contracting State shall be kept secret in the same way as information obtained under the national law of that State and shall be communicated only to the persons or authorities (including the judicial authorities) responsible for the management or collection of taxes covered by the Convention, to the declaratory or executive procedures relating to such taxes or to the resolution of appeals relating thereto. Such persons or authorities shall use the information only for such purposes.

2. In no case may the provisions of paragraph 1 be interpreted as obliging a Contracting State to:

(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 its own legislation or in the exercise of its normal administrative practice or that of the other Contracting State.

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

The provisions of this Convention do not affect the tax privileges of members of diplomatic and consular missions recognized under the general principles of international law or the provisions of special agreements.

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

2. This Convention shall enter into force at the time of the exchange of instruments of ratification and its provisions shall take effect with respect to taxes relating to tax periods beginning on or after 1 January of the calendar year following the year in which the Convention enters into force.

This Convention shall remain in force until it is denounced by one of the Contracting States. Any Contracting State may denounce the Convention by diplomatic notification at least six months before the end of any calendar year after a period of three years from the date of entry into force of the Convention. In such a case, the Convention shall cease to have effect in respect of taxes relating to tax periods beginning on or after 1 January of the calendar year following that in which the complaint occurred.

At the time of the signing of the Convention between Spain and the People's Republic of Bulgaria on the prevention of double taxation and tax evasion in the area of income and property taxes, the undersigned have agreed on the following provisions which form an integral part of the Convention.

1. The participation of a resident of Spain in a Joint Venture referred to in Article 4(4) means participation in socially constituted enterprises having the status of a legal person established under Decree 535/80 of the Council of State of the People's Republic of Bulgaria.

2. In the case of Spain, Article 8(2) shall not apply to the income attributable, whether distributed or not, to the shareholders of the Companies and Entities referred to in Article 12(2) of Law 44/1978 of 8 September and Article 19 of Law 61/1978 of 27 December, as long as that income is not subject to Spanish Company Tax. Such income may be taxed in Spain under its domestic law.

3. In order to promote economic cooperation between the two Contracting States, the competent authorities of the two Contracting States, in cases where, in order to promote economic development, a reduced rate of taxation is established in respect of the rate in force generally in a Contracting State, shall determine by amicable agreement, notwithstanding the provisions of Article 21, the method of avoiding double taxation which contributes to that purpose.

4. Each Contracting State shall apply its domestic transfer pricing legislation. Any dispute arising in this matter shall be settled by mutual agreement procedure.

In testimony of which the undersigned, duly authorized to do so, sign this Protocol.

Done at Sofia on 6 March 1990 in duplicate in the Spanish and Bulgarian languages, both texts being equally authentic.

This Convention entered into force on 14 June 1991, the date of the exchange of instruments of ratification, as set out in Article 26.2.

What is made public for general knowledge.

Madrid, 18 June 1991. Acting Technical Secretary General Aquilino González Hernando.