NOTES OF EXCHANGE TO THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE POLISH PEOPLE's REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF
颁布时间:1974-10-08
DEPARTMENT OP STATE,
Washington, October 8, 1974.
His Excellency, STEFAN OLSZOWSKI,
Minister of Foreign Affairs of the Polish People's Republic
EXCELLENCY: I have the honor to refer to the Income Tax Convention
between the Government of the United States and the Government of the
Polish People's Republic signed today in Washington. During the course of
negotiations, the question arose as to the effect of the Convention upon
the income taxes imposed by the states of the United States.
In that connection, I should like to note that the individual states
of the United States each have Constitutional authority to impose taxes
within certain limitations. In light of this authority, the Government of
the United States has not considered it appropriate to enter into income
tax conventions which restrict or limit state taxes except to prohibit any
state from imposing discriminatory taxes.
A review of the tax laws of the states of the United States indicates
that these laws generally operate in such a manner that a resident of
Poland entitled to a reduced rate of tax or to tax exemption under the
Convention would not be subject to tax by the individual states. This is
also the case as concerns Polish enterprises engaged in international
traffic of ships or aircraft. Nevertheless, I should like to assure you
that if necessary, the tax authorities of the United States will use their
best efforts to secure exemption from any income taxes that may be imposed
by any of the states of the United States on such shipping or airline
enterprises.
Accept, Excellency, the assurances of my highest consideration.
(s) Henry A. Kissinger,
Secretary of State of the
United States of America.
[TRANSLATION]
EMBASSY OF THE POLISH PEOPLE'S REPUBLIC,
Washington, October 8, 1974.
His Excellency, HENRY A. KISSINGER,
Secretary of State of the United States of America
EXCELLENCY: I have the honor to acknowledge the receipt of your letter
dated October 8, 1974, which reads as follows:
"EXCELLENCY: I have the honor to refer to the Income Tax Convention
between the Government of the United States and the Government of the
Polish People's Republic signed today in Washington. During the course of
negotiations, the question arose as to the effect of the Convention upon
the income taxes imposed by the states of the United States.
In that connection, I should like to note that the individual states
of the United States each have Constitutional authority to impose taxes
within certain limitations. In light of this authority, the Government of
the United States has not considered it appropriate to enter into income
tax conventions which restrict or limit state taxes except to prohibit any
state from imposing discriminatory taxes.
A review of the tax laws of the states of the United States indicates
that these laws generally operate in such a manner that a resident of
Poland entitled to a reduced rate of tax or to tax exemption under the
Convention would not be subject to tax by the individual states. This is
also the case as concerns Polish enterprises engaged in international
traffic of ships or aircraft. Nevertheless, I should like to assure you
that if necessary, the tax authorities of the United States will use their
best efforts to secure exemption from any income taxes that may be imposed
by any of the states of the United States on such shipping or airline
enterprises.
Accept, Excellency, the assurances of my highest consideration."
I have the honor to acknowledge the receipt of the assurances
contained in the above text.
Accept, Excellency, the expression of my highest consideration.
(s) Stefan Olszowski,
Minister of Foreign Affairs, Polish People's Republic.