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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:
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.The furnishing of services, including consultancy services, in a Contracting...
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.Insofar as it has been customary in a Contracting State...
5.No profits shall be attributed to a permanent establishment by...
6.For the purposes of the preceding paragraphs, the profits to...
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...
9.Notwithstanding the provisions of paragraph (2) of this Article, interest...
10.Notwithstanding the provisions of Article 7 of this Convention and...
11.Notwithstanding the provisions of Article 7 of this Convention and...
2.However, such royalties may also be taxed in the Contracting...
3.The term “royalties” 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...
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.Gains from the alienation of any property other than that...
6.The provisions of paragraph (5) 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...
Where, under any provision of this Convention, a partnership, joint...
1.Nationals of a Contracting State shall not be subjected in...
2.Stateless persons who are residents of a Contracting State shall...
3.The taxation on a permanent establishment which an enterprise of...
4.Except where the provisions of paragraph (1) of Article 9,...
5.Enterprises of a Contracting State, the capital of which is...
6.Nothing contained in this Article shall be construed as obliging...
7.The provisions of this Article shall apply to the taxes...
ARTICLE 28 Members and employees of diplomatic or consular establishments and permanent missions
Nothing in this Convention shall affect any fiscal privileges accorded...
Each of the Contracting States shall notify to the other...
This Convention shall remain in force until terminated by one...
In witness whereof the undersigned, duly authorised thereto, have signed...
Done in duplicate at London this 23rd day of February...
I have the honour to refer to the Convention between...
Article 2: Taxes covered
Article 4: Residence
Article 5: Permanent establishment
The Contracting States agree that the applicability of the second...
Article 8: Shipping and air transport
Article 11: Interest
Article 26: Mutual Agreement Procedure
With reference to paragraph (4), the Contracting States agree that...
Article 29: Entry into Force
In the case of any difficulties or doubts arising as...
Capital
If the foregoing proposals are acceptable to the Government of...
I avail myself of this opportunity to extend to Your...
I am in receipt of your note dated 23rd February...
The foregoing proposals being acceptable to the Government of the...
I take this opportunity to renew to Your Excellency the...
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