The Double Taxation Relief (Taxes on Income) (The Hashemite Kingdom of Jordan) Order 2001

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 in...

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 HASHEMITE KINGDOM OF JORDAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON 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. Article 1

            Personal scope

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

         5. Article 2

            Taxes covered

            1. 1. This Convention shall apply to taxes on income and on...

            2. 2. There shall be regarded as taxes on income and on...

            3. 3. The existing taxes to which this Convention shall apply are...

            4. 4. This Convention shall also apply to any identical or substantially...

         6. 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 at any time...

         7. 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...

         8. 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. The term “permanent establishment” likewise encompasses a building site, a...

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

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

            6. 6. An enterprise of a Contracting State shall not be deemed...

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

         9. 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...

         10. Article 7

             Business profits

             1. 1. The profits of an enterprise of a Contracting State shall...

             2. 2. Subject to the provisions of paragraph (3) of this Article,...

             3. 3. In determining the profits of a permanent establishment, there shall...

             4. 4. For the purposes of the preceding paragraphs, the profits to...

             5. 5. Where profits include items of income or capital gains which...

             6. 6. No profits shall be attributed to a permanent establishment by...

         11. Article 8

             Shipping and air transport

             1. 1. Profits derived by an enterprise of a Contracting State from...

             2. 2. For the purposes of this Article, profits from the operation...

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

         12. Article 9

             Associated enterprises

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

             2. 2. Where a Contracting State includes in the profits of an...

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

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

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

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

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

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

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

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

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

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

         15. 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...

         16. Article 13

             Capital gains

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

             2. 2. Gains derived by a resident of a Contracting State from...

             3. 3. Gains from the alienation of movable property forming part of...

             4. 4. Gains derived by a resident of a Contracting State from...

             5. 5. Gains from the alienation of any property other than that...

             6. 6. The provisions of paragraph (5) of this Article shall not...

         17. Article 14

             Independent personal services

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

             2. 2. The term “professional services” includes especially independent scientific, literary, artistic,...

         18. Article 15

             Dependent personal services

             1. 1. Subject to the provisions of Articles 16, 18, 19 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...

         19. Article 16

             Directors' fees

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

         20. Article 17

             Artistes and sportsmen

             1. 1. Notwithstanding the provisions of Articles 14 and 15 of this...

             2. 2. Where income in respect of personal activities exercised by an...

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

         21. Article 18

             Pensions and annuities

             1. 1. Subject to the provisions of paragraph (2) of Article 19...

             2. 2. The term “annuity” means a stated sum payable to an...

         22. Article 19

             Government service

             1. 1. (a) Salaries, wages and other similar remuneration, other than a...

             2. 2. (a) Any pension paid by, or out of funds created...

             3. 3. The provisions of Articles 15, 16, 17 and 18 of...

         23. Article 20

             Teachers and researchers

             1. 1. An individual who is immediately before visiting a Contracting State...

             2. 2. The provisions of this Article shall apply to income from...

         24. Article 21

             Students and trainees

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

         25. Article 22

             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. Where, by reason of a special relationship between the person...

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

         26. Article 23

             Elimination of double taxation

             1. 1. In the case of Jordan: Where a resident of Jordan...

             2. 2. In the case of the United Kingdom: Subject to the...

             3. 3. For the purposes of paragraph (2) of this Article, profits,...

         27. Article 24

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

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

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

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

         28. Article 25

             Mutual agreement procedure

             1. 1. Where a person considers that the actions of one or...

             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...

         29. 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...

         30. Article 27

             Members of diplomatic or permanent missions and consular posts

             1. 1. Nothing in this Convention shall affect the fiscal privileges of...

             2. 2. Notwithstanding the provisions of paragraph (1) of Article 4 of...

         31. Article 28

             Entry into force

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

             2. 2. The Agreement between the Contracting States in respect of profits...

         32. Article 29

             Termination

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

             2. In Witness whereof the undersigned, duly authorised thereto, have signed...

             3. Done in duplicate at Amman this twenty second day of...

             4. For the Government of The United Kingdom of Great Britain...

             5. For the Government of The Hashemite Kingdom of Jordan: Michel...

      2. PART II EXCHANGE OF NOTES

         1. Amman

         2. 22nd July 2001

         3. Your Excellency

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

         5. If the foregoing proposals are acceptable to the Government of...

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

         7. Michel Marto of the Hashemite Kingdom of Jordan Amman

         8. 22nd July 2001

         9. Your Excellency

         10. I have the honour to acknowledge receipt of Your Excellency’s...

         11. The foregoing proposals being acceptable to the Government of the...

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

         13. Ben Bradshaw of the United Kingdom of Great Britain and...

6. Explanatory Note