The Double Taxation Relief (Taxes on Income) (Venezuela) Order 1996

2. Introductory Text

1. This Order may be cited as the Double Taxation Relief...

3. 2. It is hereby declared — (a) that the arrangements specified...

4. Signature

5. 1. SCHEDULE

      1. PART I CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF THE REPUBLIC OF VENEZUELA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS

         1. The Government of the United Kingdom of Great Britain and...

         2. Desiring to conclude a Convention for the avoidance of double...

         3. Have agreed as follows:

         4. CHAPTER I SCOPE OF CONVENTION

            1. Article 1

               Personal scope

               1. This Convention shall apply to persons who are residents of...

            2. Article 2

               Taxes covered

               1. 1. The taxes which are the subject of this Convention are:...

               2. 2. The Convention shall also apply to any identical or substantially...

         5. CHAPTER II DEFINITIONS

            1. Article 3

               General definitions

               1. 1. For the purposes of this Convention, unless the context otherwise...

               2. 2. As regards the application of this Convention by a Contracting...

            2. Article 4

               Resident

               1. 1. For the purposes of this Convention, the term “resident of...

               2. 2. Where by reason of the provisions of paragraph (1) of...

               3. 3. Where by reason of the provisions of paragraph (1) of...

            3. Article 5

               Permanent establishment

               1. 1. For the purposes of this Convention, the term “permanent establishment”...

               2. 2. The term “permanent establishment” includes especially: (a) a place of...

               3. 3. Notwithstanding the preceding provisions of this Article, the term “permanent...

               4. 4. Notwithstanding the provisions of paragraphs (1) and (2) of this...

               5. 5. An enterprise shall not be deemed to have a permanent...

               6. 6. The fact that a company which is a resident of...

         6. CHAPTER III TAXATION OF INCOME

            1. Article 6

               Income from immovable property

               1. 1. Income derived by a resident of a Contracting State from...

               2. 2. The term “immovable property” shall have the meaning which it...

               3. 3. The provisions of paragraph (1) of this Article shall apply...

               4. 4. The provisions of paragraphs (1) and (3) of this Article...

            2. Article 7

               Business profits

               1. (1) The profits of an enterprise of a Contracting State...

            3. Article 8

               Shipping and air transport

               1. (1) Profits derived by a resident of a Contracting State...

            4. Article 9

               Associated enterprises

               1. (1) Where: (a) an enterprise of a Contracting State participates...

            5. Article 10

               Dividends

               1. 1. Dividends paid by a company which is a resident of...

               2. 2. However, such dividends may also be taxed in the Contracting...

               3. 3. Notwithstanding paragraph (2) of this Article, the Contracting State of...

               4. 4. The term “dividends” as used in this Article means income...

               5. 5. The provisions of paragraphs (1), (2) and (3) of this...

               6. 6. Where a company which is a resident of a Contracting...

               7. 7. The provisions of this Article shall not apply if it...

            6. Article 11

               Interest

               1. 1. Interest arising in a Contracting State and paid to a...

               2. 2. However, such interest may also be taxed in the Contracting...

               3. 3. Notwithstanding the provisions of paragraph (2) of this Article, interest...

               4. 4. Notwithstanding the provisions of Article 7 of this Convention and...

               5. 5. The term “interest” as used in this Article means income...

               6. 6. The provisions of paragraphs (1), (2) and (3) of this...

               7. 7. Interest shall be deemed to arise in a Contracting State...

               8. 8. Where, by reason of a special relationship between the payer...

               9. 9. The provisions of this Article shall not apply if it...

               10. 10. For the purposes of this Article the following residents of...

            7. Article 12

               Royalties

               1. 1. Royalties arising in a Contracting State and paid to a...

               2. 2. However, such royalties may also be taxed in the Contracting...

               3. 3. The term “royalties” as used in this Article means payments...

               4. 4. The provisions of paragraphs (1) and (2) of this Article...

               5. 5. Royalties shall be deemed to arise in a Contracting State...

               6. 6. Where, by reason of a special relationship between the payer...

               7. 7. The provisions of this Article shall not apply if it...

               8. 8. For the purposes of this Article the following residents of...

            8. Article 13

               Capital gains

               1. (1) Gains derived by a resident of a Contracting State...

            9. Article 14

               Independent personal services

               1. 1. Income derived by a resident of a Contracting State in...

               2. 2. The term “professional services” includes among others independent scientific, literary,...

            10. Article 15

                Dependent personal services

                1. 1. Subject to the provisions of Article s 16, 18 and...

                2. 2. Notwithstanding the provisions of paragraph (1) of this Article, remuneration...

                3. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in...

            11. Article 16

                Director’s fees

                1. Directors' fees and other similar payments derived by a resident...

            12. Article 17

                Artistes and athletes

                1. (1) Notwithstanding the provisions of Article s 14 and 15...

            13. Article 18

                Pensions and annuities

                1. 1. Pensions and other similar remuneration and any annuity paid in...

                2. 2. The term “annuity” means a stated sum payable periodically at...

            14. Article 19

                Government service

                1. (1)(a) Remuneration, other than a pension, paid by a Contracting...

            15. Article 20

                Students

                1. Payments which a student or business apprentice who is or...

            16. Article 21

                Other income

                1. 1. Items of income beneficially owned by a resident of a...

                2. 2. The provisions of paragraph (1) of this Article shall not...

                3. 3. Notwithstanding the provisions of paragraphs (1) and (2) of this...

                4. 4. Where, by reason of a special relationship between the resident...

                5. 5. The provisions of this Article shall not apply if it...

         7. CHAPTER IV METHODS FOR THE ELIMINATION OF DOUBLE TAXATION

            1. Article 22

               Elimination of double taxation

               1. (1) Subject to the provisions of the law of the...

            2. Article 23

               Non-discrimination

               1. 1. Nationals of a Contracting State shall not be subjected in...

               2. 2. The taxation on a permanent establishment which an enterprise of...

               3. 3. Except where the provisions of paragraph (1) of Article 9,...

               4. 4. Enterprises of a Contracting State, the capital of which is...

               5. 5. Nothing contained in this Article shall be construed as obliging...

               6. 6. The provisions of this Article shall apply to the taxes...

            3. Article 24

               Partnerships

               1. Where, under any provision of this Convention, a partnership is...

            4. Article 25

               Mutual agreement procedure

               1. 1. Where a resident of a Contracting State considers that the...

               2. 2. The competent authority shall endeavour, if the objection appears to...

               3. 3. The competent authorities of the Contracting States shall endeavour to...

               4. 4. The competent authorities of the Contracting States may communicate with...

            5. Article 26

               Exchange of information

               1. 1. The competent authorities of the Contracting States shall exchange such...

               2. 2. In no case shall the provisions of paragraph (1) of...

            6. Article 27

               Members of diplomatic or permanent missions and consular posts

               1. Nothing in this Convention shall affect any fiscal privileges accorded...

            7. Article 28

               Entry into force

               1. 1. Each of the Contracting States shall notify to the other,...

               2. 2. The existing Agreement for the Avoidance of Double Taxation in...

            8. Article 29

               Termination

               1. This Convention shall remain in force indefinitely until terminated by...

               2. Done in duplicate at Caracas this 11th day of March,...

      2. PART II EXCHANGE OF NOTES

         1. Your Excellency

         2. I have the honour to refer to the Convention between...

         3. Article 4

         4. Article s 7 and 14

         5. Article 8

         6. If the following proposal is acceptable to the Government of...

         7. I avail myself of this opportunity to extend to Your...

         8. Your Excellency

         9. I am in receipt of your note dated 11th March...

         10. The foregoing proposal being acceptable to the Government of the...

         11. I take this opportunity to renew to Your Excellency the...

6. Explanatory Note