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I. EXAMINATION OF RECENTLY CONCLUDED INTERNATIONAL CONVENTIONS FOR THE AVOIDANCE OF DOUBLE TAXATION.

On February 22nd, 1928, Hungary and Yugoslavia concluded a Conventionnote for the prevention of double taxation in the matter of direct taxes (including contributions levied on account of subordinate public corporations, communes, etc.). The Convention is based on the distinction between impersonal and personal taxes, both the terms being interpreted in their ordinary sense.

In so far as concerns important taxes, the Convention follows the principles embodied in the 1928 model conventions. There is a slight difference as regards directors' fees: if these are paid in respect of services at a branch, the State in whose territory the branch is situated has the right of assessment (compare Article 7 of the Convention with Article 6 of draft Ia.). It may be noted further that under Articles 6 and 7, in determining the domicile of juridical persons, not only the real centre of management of the undertaking (vide Article 4 of draft Ia) but also the head office of the company is taken into account, the latter having priority over the said centre of management. This stipulation recurs in Article 9 (personal tax).

In principle, the personal tax is levied in the taxpayer's State of domicile, with the exception of income from immovable property (including mortgage debts) and industrial and commercial undertakings, and earned income (the latter forms of income are not excepted in the above-mentioned article in draft Ia). The tax on total wealth is based on the same principles as the personal tax on income. As regards administrative and legal assistance, there is only one provision dealing with this matter (Article 14).

As regards the exemption of shipping, the Committee can mention, in addition to Article 12 of the above-mentioned Treaty, seven Agreements: between Belgium and Sweden (May 31st, 1929), Canada and Japan (September 21st, 1929, Exchange of Notes), Canada and the Netherlands September 2 [?], 1929, Exchange of Notes), Canada and Greece (September 30th, 1929, Exchange of Notes), Canada and Sweden (November 21st, 1929, Exchange of Notes), France and Sweden (December 19th, 1929, January 25th, 1930, Exchange of Notes), Canada and Germany (April 17th, 1930, Exchange of Notes).

Total or partial exemption from the road-tax has been provided for in arrangements between the Netherlands and certain other countries—namely, Belgium, Denmark, Germany, Great Britain and Northern Ireland, and Sweden. These arrangements have been brought into operation by enactment of simultaneous internal legislation

Finally, a Treaty [?] was concluded between Austria and Hungary (June 25th, 1928), providing for administrative and legal assistance; the whole of this Treaty corresponds to the Treaty between Austria and Czechoslovakia of July 12th, 1926 (document C.345.M.102.1928.II, p. 224).

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