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2.It is hereby declared— (a) that the arrangements specified in...
The Government of the United Kingdom of Great Britain and...
Desiring to conclude a Convention for the avoidance of double...
Have agreed as follows:
CHAPTER I SCOPE OF THE CONVENTION
This Convention shall apply to persons who are residents of...
ARTICLE 5 Permanent establishment
1.For the purposes of this Convention the term “permanent establishment”...
2.The term “permanent establishment” includes especially: (a) a place of...
3.Notwithstanding the preceding provisions of this Article, the term “permanent...
4.Notwithstanding the provisions of paragraphs (1) and (2) of this...
5.An enterprise of a Contracting State shall not be deemed...
CHAPTER III TAXATION OF INCOME
1.The profits of an enterprise of a Contracting State shall...
2.Subject to the provisions of paragraph (3) of this Article,...
3.In the determination of the profits of a permanent establishment,...
4.No profits shall be attributed to a permanent establishment by...
5.For the purposes of the preceding paragraphs, the profits to...
6.The provisions of this Article shall not affect the application...
7.Where profits include items of income or capital gains which...
2.However, such interest may also be taxed in the Contracting...
3.The term “interest” as used in this Article means income...
4.The provisions of paragraphs (1) and (2) of this Article...
5.Interest shall be deemed to arise in a Contracting State...
6.Where, by reason of a special relationship between the payer...
8.Notwithstanding the provisions of paragraph (2) of this Article, interest...
9.Notwithstanding the provisions of Article 7 of this Convention and...
2.However, such royalties may also be taxed in the Contracting...
3.The term “royalities” as used in this Article means payments...
4.The provisions of paragraphs (1) and (2) of this Article...
5.Royalties shall be deemed to arise in a Contracting State...
6.Where, by reason of a special relationship between the payer...
Directors' fees and other similar payments derived by a resident...
ARTICLE 20 Students and trainees
An individual who is or was a resident of a...
1.Nationals of a Contracting State shall not be subjected in...
2.The taxation on a permanent establishment which an enterprise of...
3.Except where the provisions of paragraph (1) of Article 9,...
4.Enterprises of a Contracting State, the capital of which is...
5.Nothing in this Article shall be construed as obliging a...
6.The provisions of this Article shall apply to the taxes...
ARTICLE 28 Diplomatic and Consular Officials
Nothing in this Convention shall affect the fiscal privileges of...
This Convention shall remain in force until terminated by one...
In witness whereof the undersigned, being duly authorised thereto by...
Done at London this 12th day of May 1994 in...
I have the honour to refer to the Convention between...
If the foregoing proposals are acceptable to the Government of...
I have the honour to acknowledge receipt of Your Excellency’s...
The foregoing proposals being acceptable to the Government of Malta,...
I avail myself of this opportunity to extend to Your...
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