Ν. 2279/1995

Ν. 2279/1995 (ΦΕΚ A 9/26-01-1995) Convention for the avoidance of double taxation between Greece and Romania

CONVENTION

between the Hellenic Republic and Romania for the avoidance of double taxation with respect to taxes on income and on capital

The Government of the Hellenic Republic

and

the Government of Romania

Desiring to promote and strengthen the economic relations between the two countries on the basis of national sovereignty and respect of independence, equality in rights, reciprocal advantage and non-interference in domestic matters; have agreed as follows:

In witness whereof the undersigned, duly authorized thereto, have signed this Convention .

Done at Athens, on 17.09.91 in originals, in the Hellenic, Romanian and English languages each text being equally authentic, the English text prevailing in case of doubt.

For the Government     For the Government

of the Hellenic Republic    of Romania

PROTOCOL

At the signing today of the Convention between the Government of the Hellenic Republic and the Government of Romania for the avoidance of double taxation with respect to taxes on income and on capital the undersigned have agreed upon the following provi­sions which shall form an integral part of the convention.

Ad Article 10

It is agreed that, since the difference between the provisions of sub-paragraph a) and those of sub-paragraph b) of paragraph 2 of Article 10 is based on the fact that according to the Hellenic income tax on legal entities as in force at the date of signature of the Convention dividends paid by a company which is a resident of the Hellenic Republic are deductible in the computation of the profits of the company paying the dividends, the two Governments will undertake the review of the provisions of paragraph 2 when the basis of such difference no longer exists: Until the review has been completed the aggregate Hellenic tax on dividends and - on the profits out of which the dividends are paid shall not exceed 45 per cent.

In witness whereof the undersigned, duly authorized thereto, have signed this Protocol.

Done at Athens, on 17.09.91 in originals, in the Hellenic, Romanian and English languages each text being equally authentic, the English text prevailing in case of doubt.

For the Government     For the Government

of the Hellenic Republic    of Romania