Message to the Senate Transmitting the Spain-United States Convention on Taxation and Fiscal Evasion

To the Senate of the United States:

I transmit herewith for Senate advice and consent to ratification the Convention between the United States of America and the Kingdom of Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, together with a related Protocol, signed at Madrid on February 22, 1990. I also transmit the report of the Department of State.

The convention is the first income tax treaty to be negotiated between the United States and Spain. Based in large part on model income tax treaties developed by the Department of the Treasury and the Organization for Economic Cooperation and Development, it also reflects changes in tax law resulting from the enactment of the Tax Reform Act of 1986.

The convention provides rules governing the taxation by each State of income derived by residents of the other State. The convention also contains provisions that prevent "treaty shopping" and authorize the exchange of information and administrative cooperation between the tax authorities of the two States.

I recommend that the Senate give early and favorable consideration to the convention and protocol and give its advice and consent to ratification.

George Bush

The White House,

April 18, 1990.