Current Economic Developments, Lot 70D467

Extract From Bulletin No. 174, October 25, 1948


Taxation Treaty Program Reviewed

The US is proceeding with its program of negotiating treaties with other countries to avoid double taxation and to promote administrative [Page 951] cooperation in the assessment and collection of taxes. There are in effect at the present time six tax conventions with four different countries—treaties dealing with income taxes with Sweden, France, Canada, and the UK, and those covering death taxes with Canada and UK. Treaties for the avoidance of double taxation of income have been signed with Netherlands and Denmark, and approved, with reservations, by the US Senate. They are now awaiting action by the parliaments of the respective countries,1 A treaty with France, revising the income tax treaty of 1939, which will remain in effect, and covering estate taxes in addition, has also been approved by the US Senate, but similar action has not yet been taken by France. We have arrived at various stages in the development of conventions with South Africa, New Zealand, Belgium, Luxembourg, Mexico and Australia. Negotiations with Italy, Greece, Norway, and Eire have been agreed upon and are expected to start during late 1948 and 1949.

A convention for the avoidance of the double taxation of incomes by the US and Union of South Africa was signed in December 1946, while one on the double taxation of estates was signed by the two countries in April 1947. Both of these treaties, as well as a treaty with New Zealand, are now pending before the US Senate Foreign Relations Committee.

A draft income tax convention with Belgium, which was preliminarily formulated in 1946, has now been finally agreed upon, and is expected to be signed shortly. Final agreement is being sought on a similar convention with Luxembourg and this agreement and the signing of the convention, as well, are anticipated for the, near future. It is hoped that both conventions will be signed in time for submittal early in the first session of the eighty-first Congress.

Tax treaty negotiations with Mexico were carried through an advanced drafting stage by mid-1947, since which time no further progress has been made. Negotiations are again planned for early 1949 with the hope that a convention can be concluded.

Discussions looking toward the negotiation of a tax treaty or treaties between Australia and the US have been conducted by informal correspondence between high tax officials of the two countries over a considerable period of time. However, when the possibility of negotiating such treaties was considered in the Australian cabinet the latter, without quite closing the door, indicated that there was little need or basis for a treaty on income taxes, but some possibility in relation to estate taxes. The US reply to an Australian note outlining this position urged that, while we could not state exactly what form the conventions would [Page 952] take nor what items they might cover, a technical mission be authorized to discuss both income and estate tax conventions.

A US mission has just departed for Rome and Athens to start negotiations leading to the conclusion of tax conventions with Italy and Greece. Discussions with Eire and Norway are expected to take place during the early part of 1949.

Much consideration was given to tax conventions in preparing the agenda for the Ninth International Conference of American States held at Bogotá last spring. Circumstances prevented full discussion of this topic in the conference, but an article in the Economic Agreement of Bogotá provides that the member states shall negotiate conventions for the avoidance of double taxation. The Economic Agreement has not yet been ratified and put into effect, and discussions with individual countries have not yet ripened into the negotiation stage, except in the case of Mexico, cited above.

Income and estate tax conventions were being negotiated with the Philippines in 1947, but no final agreement was reached at that time. Negotiations have been suspended and it is not known whether they will be resumed.

  1. On November 12, 1948, the Danish Parliament approved the double taxation convention with the United States.