The Greek Minister (Simopoulos) to the Secretary of State
The Minister of Greece, in presenting his most cordial compliments to His Excellency the Secretary of State, has the honor to inform him that he has been authorized by his Government to set on foot negotiations for the conclusion of an agreement relative to the exemption of nationals of both countries [from the income tax] on the profits derived from maritime enterprises, on the basis of reciprocity.
Greek law contains the following exemptions on this subject:
- Article 30, paragraph 8 of Law No. 3338 of June 15, 1925:
“The ordinance in paragraph 7 of article 3 of this law has retroactive effect with respect to the income tax of the years 1919–1920 up to 1924–1925, as well as that of excess profits of the year 1915 and the following years, and also with respect to the additional tax on corporations of the year 1921 and the following years.”
- The ordinance of article 3, paragraph 7 of Law No. 3338
above-mentioned, ends as follows:
“To paragraph 3 of article 18 of Law 1640 concerning the taxation of income there is added as the sixth case the following exemption. Sixth case: ‘In virtue of reciprocity, profits made in Greece by vessels flying a foreign flag.’”
The two ordinances mentioned above guarantee the exemption of shipping concerns in virtue of reciprocity.
The income tax has been in force since 1919–1920, that is to say, since the date for which retroactive effect was stipulated in the law. The tax on excess profits was in force from 1915 until 1923, and the additional tax on corporations from 1921 until 1924.
Since the reciprocity principle on this subject was recognized by the law of the United States, the Minister of Greece takes the liberty of submitting the enclosed draft2 for a settlement of this question with [Page 84]a request that His Excellency the Secretary of State will kindly give it favorable attention.
Since the National Navigation Company of Greece has an agency in New York, styled National Steam Navigation Company, Limited, of Greece, at 20 Pearl Street, the Minister of Greece would be infinitely obliged if His Excellency would kindly forward to the proper authorities the needful instructions to suspend any action about the levying of a tax flowing from the above-mentioned obligations during the course of the negotiations bearing on the settlement of this question.