APPENDIX "An American corporation which wishes to place itself under the regime of the preceding paragraph must make a declaration to that effect at the Bureau of Registration jointly with the interested French corporation, within six months after the date upon which this agreement becomes effective or within six months after the acquisition of the participation or the commencement of the relations of a nature to entail the application of article 3 of the decree of December 6, 1872. Any such election is irrevocable. "American corporations which have not made the declaration and which are subjected to the provisions of article 3 of the decree of December 6, 1872, shall enjoy the benefits of articles 27, 28 and 29 of the French law of July 31, 1920, and article 25 of the French law of March 19, 1928, under the same conditions as French corporations. "ATICLE VIr "Compensation paid by one of the contracting States to its citizens for labor or personal services performed in the other State is exempt from tax in the latter State. 'ABTICL VIII "War pensions paid by one of the contracting States to persons residing in the territory of the other State are exempt from tax in the latter State. "ARTICLE IX "The following classes of income paid in one of the contracting States to a corporation of the other State, or to a citizen of the latter State residing there, are exempt from tax in the former State: "(a) amounts paid as consideration for the right to use patents, secret processes and formulas, trade marks and other analogous rights; "(b) income received as copyright royalties; "(c) private pensions and life annuities. "ARTICLE x "This agreement shall be ratified and the instruments of ratification exchanged at Paris as soon as possible. "The agreement shall become effective on the 1st day of January following the exchange of ratifications and shall remain effective for a period of 5 years, and thereafter until 12 months from the date on which either contracting party gives notice of its termination. "American corporations which prior to May 1, 1930, have not had their lia- bility to tax under article 3 of the decree of December 6, 1872, finally deter- mined, and which make the declaration prescribed in Article VI of the present convention, shall not be subject to the application of article 3 of the decree of December 6, 1872, for any years preceding the coming into force of the agreement. "In witness whereof, the respective plenipotentiaries have signed the above articles, both in the English and French languages, and have hereunto affixed their seals. "Done in duplicate at Paris, on the 27th of April, 1932. "[s8EAL] WALTER E. EDGn. "[swAL] ANDBa TaaDIu. " PROTOCOL "At the moment of signing the Convention on Double Taxation between the United States of America and the Republic of France, the undersigned plenipo- tentiaries, duly authorized by their respective Governments, have agreed, as follows: "(1) The taxes referred to in this agreement are: "(a) for the United States: the Federal income tax-but it is understood that Article I does not exempt from tax (1) compensation for labor or personal services performed in the United States; (2) income derived from real property located in the United States, or from'any interest in such property, including rentals and royalties therefrom, and gains from the sale or the disposition thereof; (3) dividends; (4) interest. "(b) For France: -- in Articles I, II, III and IV, the tax on industrial and commercial profits (impot sur les benefices industriels et commerciaux); "-in Articles UI, V and VI, the tax on income from securities (impOt sur lea revenues des valeurs mobilleres); "-in Articles VII, VIII and IX, the tax on wages and salaries, pensions and life annuities (impOt sur les traitements et salaires, pensions et rentes viag- CLXXXVII
�
