For Immediate Release
Office of the Press Secretary
July 16, 2004
Message to the Senate of the United States
TO THE SENATE OF THE UNITED STATES:
I transmit herewith for Senate advice and consent to ratification,
the Protocol Amending the Convention Between the United States of
America and the Kingdom of the Netherlands for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on
Income, signed at Washington, D.C., on March 8, 2004. Transmitted for
the Senate's information is an exchange of notes with an attached
Understanding, which provides clarification with respect to the
application of the Convention, as amended, in specific cases. Also
transmitted for the information of the Senate is the report of the
Department of State with respect to the Protocol.
The Protocol would bring the existing Convention into closer
conformity with current U.S. tax treaty policy. As modified by the
Protocol, the Convention would be similar to tax treaties between the
United States and other developed nations. The Protocol was concluded
in recognition of the importance of the United States' economic
relations with the Netherlands.
The Protocol would modify the treatment of certain cross-border
dividend payments and would modernize the Convention's
anti-treaty-shopping provisions. The Protocol also would liberalize
provisions in the existing Convention regarding the mutual recognition
of each country's pension plans. Other provisions in the Protocol
update the Convention to take account of changes in law in the two
countries over the last 10 years. The exchange of notes with an
attached Understanding provides guidance to taxpayers and each
government regarding the intended interpretation of certain provisions
of the existing Convention, as amended.
I recommend that the Senate give early and favorable consideration
to this Protocol, and that the Senate give its advice and consent to
ratification.
GEORGE W. BUSH
THE WHITE HOUSE,
July 16, 2004.
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