EMBASSY OF THE UNITED STATES OF AMERICA, Nicosia, March 19, 1984. No.027 His Excellency, GEORGE IACOVOU, Minister of Foreign Affairs of The Republic of Cyprus. 　　EXCELLENCY: I have the honor to refer to the Convention between the Government of the United States of America and the Government of the Republic of Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income which has been signed on this date. Two questions arose with respect to which it was deemed appropriate to exchange Notes recording the agreement reached by the delegation from our two countries. 　　Both Governments agree to exchange such information as is pertinent to carrying out the provisions of the Convention and of the domestic laws of the Contracting States concerning taxes covered by the Convention. The United States presently has the full authority within its internal law to implement this agreement. With respect to Cyprus, the Convention will provide the necessary authority to implement the Convention to the extent such authority appears to be lacking in the internal law of Cyprus. 　　This will include the following types of information: 　　(1) Bank information in the custody of a taxpayer; 　　(2) Information in the custody of a bank; 　　(3) Information in the possession of the Central Bank relating to beneficial stock ownership; 　　(4) Information in the possession of the registered legal owner of a corporation relating to beneficial stock ownership; 　　(5) Information in the possession of a trustee relating to beneficial ownership.In the event that the person from whom information is requested does not disclose such information, 　　it is understood that under the law of Cyprus civil and criminal sanctions can be imposed.In view of the expressed interest of Cyprus in promoting investment in Cyprus, it is agreed that at such time as the United States is in a position to do so, discussions will be resumed with a view to incorporating provisions into this Convention that will minimize the interference of the U.S. tax system with incentives offered by the Government of Cyprus and that will be consistent with the income tax policies of the United States Government regarding other developing countries. 　　I have the honor to propose to you that the present Note and your reply thereto constitute the agreement of our two Governments on these points. 　　Accept, Excellency the renewed assurances of my highest consideration. 　　　　 　 RAYMOND C. EWING. 　　　　 REPUBLIC OF CYPRUS, 　　　　　 MINISTRY OF FOREIGN AFFAIRS, March 19, 1984. No. 850/69. His Excellency, Mr. R. C. EWING, Ambassador of the United States of America, Nicosia. EXCELLENCY, I have the honor to refer to your Note dated March 19, 1984, addressed to the Minister of Foreign Affairs, which reads as follows: 　　"Excellency, I have the honor to refer to the Convention between the Government of the United States of America and the Government of the Republic of Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income which has been signed on this date. Two questions arose with respect to which it was deemed appropriate to exchange Notes recording the Agreement reached by the delegations from our two countries. 　　Both Governments agree to exchange such information as is pertinent to carrying out the provisions of the Convention and of the domestic laws of the Contracting States concerning taxes covered by the Convention. The United States presently has the full authority within its internal law to implement this agreement. With respect to Cyprus, the Convention will provide the necessary authority to implement the Convention to the extent such authority appears to be lacking in the internal law of Cyprus. 　　This will include the following types of information: 　　(1) bank information in the custody of a taxpayer; 　　(2) information in the custody of a bank; 　　(3) information in the possession of the Central Bank relating to beneficial stock ownership; 　　(4) information in the possession of the registered legal owner of a corporation relating to beneficial stock ownership; 　　(5) information in the possession of a trustee relating to beneficial ownership. 　　In the event that the person from whom information is requested does not disclose such information, it is understood that under the law of Cyprus, civil and criminal sanctions can be imposed. In view of the expressed interest of Cyprus in promoting investment in Cyprus, it is agreed that at such time as the United States is in a position to do so, discussions will be resumed with a view to incorporating provisions into this convention that will minimize the interference of the U.S. tax system with incentives offered by the Government of Cyprus and that will be consistent with the income tax policies of the United States Government regarding other developing countries. 　　I have the honor to propose to you that the present Note and your reply thereto constitute the Agreement of our two Governments on these points. 　　Accept, Excellency, the renewed assurances of my highest consideration." 　　The Government of the Republic of Cyprus agrees with the contents of your Note above and thus this Note together with your Note of March 19, 1984, constitutes the Agreement between our two Governments entering into force on this date of March 19, 1984. 　　Accept, Excellency the assurances of my highest consideration. V. MARKIDES, Ag. Director General, Ministry of Foreign Affairs, Republic of Cyprus.