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Decree No. 2009-725 Of 18 June 2009 On The Publication Of The Agreement By Exchange Of Notes Between The Government Of The French Republic And The Government Of The Kingdom Of Saudi Arabia For The Renewal Of The Convention For The Avoidance Of The D...

Original Language Title: Décret n° 2009-725 du 18 juin 2009 portant publication de l'accord par échange de notes entre le Gouvernement de la République française et le Gouvernement du Royaume d'Arabie saoudite pour la reconduction de la convention en vue d'éviter les d...

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Summary

Application of art. 52 to 55 of the Constitution.

Keywords

AFFAIRS AND EUROPEAN , INTERNATIONAL AGREEMENT , BILATERAL AGREEMENT , FRANCE , SAUDI ARABIA , IMPOSITION , IMPOSITION DOUBLE IMPOSITION , FISCALE EVASION , FISCALE FRAUDE , IMPOT , IMPOT SUR LE REVENU , IR , IMPOT SUR LES SUCCESSION , ECHANGE


JORF n°0141 of 20 June 2009 page 10069
text No. 35



Decree No. 2009-725 of 18 June 2009 on the publication of the agreement by exchange of notes between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia for the renewal of the agreement with a view to avoiding double taxation on income tax and estates signed on 18 February 1982, signed in Paris on 27 November 2008 and 30 December 2008 (1)

NOR: MAEJ0913391D ELI: https://www.legifrance.gouv.fr/eli/decret/2009/6/18/MAEJ0913391D/jo/texte
Alias: https://www.legifrance.gouv.fr/eli/decret/2009/6/18/2009-725/jo/texte


President of the Republic,
On the report of the Prime Minister and the Minister for Foreign and European Affairs,
Seen them Articles 52 to 55 of the Constitution ;
Vu le Decree No. 53-192 of 14 March 1953 amended on the ratification and publication of international commitments undertaken by France;
Vu le Decree No. 83-586 of 28 June 1983 publishing the agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia with a view to avoiding double taxation on income and inheritance taxes (a protocol package), signed in Paris on 18 February 1982;
Vu le Decree No. 89-375 of 12 June 1989 publishing the agreement in the form of an exchange of letters between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia, renewing the agreement of 18 February 1982 with a view to avoiding double taxation on income and inheritance taxes (a whole protocol), signed on 20 December 1988 and 22 February 1989;
Vu le Decree No. 95-987 of 28 August 1995 publishing the agreement in the form of an exchange of letters between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia on the extension of the agreement of 18 February 1982 with a view to avoiding double taxation on income and inheritance taxes, signed on 3 January 1994 and 3 May 1995;
Vu le Decree No. 95-988 of 28 August 1995 issuing the amendment to the 18 February 1982 agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia with a view to avoiding double taxation on income and inheritance taxes (a combination of interpretative letters signed on 16 June and 31 October 1993), signed in Riyadh on 2 October 1991;
Vu le Decree No. 99-453 of 28 May 1999 issuing the agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia to renew the agreement of 18 February 1982 with a view to avoiding double taxation on income tax and succession, in the form of an exchange of letters signed in Paris on 9 September 1998 and in Riyadh on 2 January 1999;
Vu le Decree No. 2003-1231 of 17 December 2003 publishing the agreement in the form of an exchange of letters between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia on the renewal of the agreement of 18 February 1982 with a view to avoiding double taxation in respect of income and inheritance taxes (as a whole protocol), signed on 14 April and 6 July 2003,
Decrete:

Article 1


The agreement by exchange of notes between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia for the renewal of the agreement with a view to avoiding double taxation on income taxes and estates signed on 18 February 1982, signed in Paris on 27 November 2008 and 30 December 2008, will be published in the Official Journal of the French Republic.

Article 2


The Prime Minister and the Minister for Foreign and European Affairs are responsible for the execution of this decree, which will be published in the Official Journal of the French Republic.

  • Annex



    A N N E X E


    AGREEMENT BY ECHANGE OF NOTES TO THE GOVERNMENT OF THE FRANÇAISE REPUBLIC AND THE GOVERNMENT OF THE SAUDI ARAB ROYAUME FOR THE RECONDUCTION OF THE CONVENTION TO SEE IMPROVED IMPOSITION DOUBLES IMPOSTS ON THE REVENUE AND ON SUCCESSIONS SIGNED ON 18 FEBRUARY 1982, SIGNED TO PARIS ON 27 NOVEMBER 2008 AND 30 DECEMBER 2008


    AMBASSADE DU ROYAUME
    OF SAUDI ARABIA
    PARIS


    Paris, 27 November 2008


    The Embassy of the Kingdom of Saudi Arabia in France presents its compliments to the Ministry of Foreign Affairs and has the honour to inform it through diplomatic channels that the Government of the Kingdom of Saudi Arabia accepts the extension of the Convention with a view to avoiding double taxation in respect of income and inheritance taxes, concluded with the Government of the French Republic and signed on 18 February 1982, as well as the annexed Protocol.
    As stipulated in Article 20, paragraph 3, of the Convention, the renewal will be for a period of five years, effective January 1, 2009.
    The Embassy requests the Ministry to inform the competent authorities and takes this opportunity to renew the assurances of its high consideration.
    Ministry of Foreign Affairs
    Protocol
    57, boulevard des Invalides,
    75007 Paris


    FRENCH REPUBLIC


    Highness,
    In response to the note verbale No.MH/NT/96/33/1047 of the Embassy of the Kingdom of Saudi Arabia in Paris dated 27 November 2008, I have the honour, by order of my Government, to inform you that France accepts the renewal of the Convention with a view to avoiding double taxation in respect of taxes on income and on the successions concluded with the Government of the Kingdom of Arabia 18
    As provided for in Article 20, paragraph 3, of the Convention, the renewal will take effect on 1 January 2009 for a period of five years.
    This letter and the above-mentioned note constitute the agreement between our two Governments on the renewal of the amended convention, which will enter into force on 1 January 2009.
    It is in this spirit that I pray Your Royal Highness to accept the assurance of my high consideration.


    Bernard Kouchner


    His Royal Highness
    Prince Saoud Al Fayçal,
    Minister of Foreign Affairs
    Kingdom of Saudi Arabia


Done in Paris, June 18, 2009.


Nicolas Sarkozy


By the President of the Republic:


The Prime Minister,

François Fillon

Minister for Foreign Affairs

and European,

Bernard Kouchner

(1) This Agreement entered into force on 1 January 2009.
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