October 2, 1985

To the Senate of the United States:

I transmit herewith for Senate advice and consent to ratification the Convention between the Government of the United States of America and the Government of the Democratic Socialist Republic of Sri Lanka for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed at Colombo on March 14, 1985. I also transmit the report of the Department of State on the Convention.

The Convention is the first income tax treaty to be negotiated between the United States and Sri Lanka. It is based on model income tax treaties developed by the Department of the Treasury and the Organization for Economic Cooperation and Development. The Convention deviates from these models, however, in several significant respects, as indicated in the attached report of the Department of State, to reflect Sri Lanka's status as a developing country. These deviations generally provide for broader source country right to tax than is found in the model treaties.

Among the principal features of the Convention are provisions to prevent third-country residents from taking unwarranted advantage of the treaty. Also included are the usual articles on nondiscrimination, mutual agreement, and exchange of information.

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

Ronald Reagan
The White House,
October 2, 1985.