SCHEDULE Fourth Protocol Amending the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Signed at London on 22 May 1968, as Modified by the Protocols Signed at London on 10 February 1971, 14 May 1973 and 12 June 1986

Article 3

Paragraph (1) of Article 3 of the Convention shall be deleted and replaced by the following:

“(1) For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.”