2.It is hereby declared— (a) that the arrangements specified in...
The Government of the United Kingdom of Great Britain and...
Desiring to conclude an Agreement for the avoidance of double...
Have agreed as follows:
This Agreement shall apply to persons who are residents of...
ARTICLE 5 Permanent establishment
1.For the purposes of this Agreement, the term “permanent establishment”...
2.The term “permanent establishment” includes especially: (a) a place of...
3.A building site or construction or installation project constitutes a...
4.Notwithstanding the preceding provisions of this Article, the term “permanent...
5.Notwithstanding the provisions of paragraphs (1) and (2) of this...
1.The profits of an enterprise of a Contracting State shall...
2.Subject to the provisions of paragraph (3) of this Article,...
3.In determining the profits of a permanent establishment, there shall...
4.No profits shall be attributed to a permanent establishment by...
5.Where profits include items of income or capital gains which...
6.Insofar as it has been customary in a Contracting State...
7.For the purposes of the preceding paragraphs, the profits to...
1.Gains derived by a resident of a Contracting State from...
2.Gains derived by a resident of a Contracting State from...
3.Gains from the alienation of movable property forming part of...
4.Gains derived by a resident of a Contracting State from...
5.With respect to gains derived by Gulf Air, the provisions...
6.Gains from the alienation of any property other than that...
7.The provisions of paragraph (6) of this Article shall not...
Directors' fees and other similar payments derived by a resident...
Payments which a student or business apprentice who is or...
ARTICLE 23 Limitation of relief
Notwithstanding the provisions of any other Article of this Agreement,...
Where, under any provision of this Agreement, a partnership is...
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 contained in this Article shall be construed as obliging...
6.The provisions of this Article shall apply to the taxes...
ARTICLE 28 Members of diplomatic or permanent missions and consular posts
This Agreement shall remain in force until terminated by one...
In witness whereof the undersigned, duly authorised thereto (by their...
Done in duplicate at London the 23rd day of February...
For the Government of the United Kingdom of Great Britain...
Your Excellency
London 23rd February 1998
I have the honour to refer to the Agreement between...
If the foregoing proposals are acceptable to the Government of...
I avail myself of this opportunity to extend to Your...
I have the honour to acknowledge receipt of Your Excellency’s...
The foregoing proposals being acceptable to the Government of the...
Minister of State United Kingdom of Great Britain and Northern...