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...
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.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...
6.An enterprise of a Contracting State shall not be deemed...
1.The profits of an enterprise of a Contracting State shall...
2.Where an enterprise of a Contracting State carries on business...
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...
Article 9 Associated enterprises
Where (a) an enterprise of a Contracting State participates directly...
2.However, such interest may also be taxed in the Contracting...
3.Notwithstanding the provisions of paragraph (2) of this Article, interest...
4.The term “interest” as used in this Article means income...
5.The provisions of paragraphs (1) and (2) of this Article...
6.Interest shall be deemed to arise in a Contracting State...
7.Where, by reason of a special relationship between the payer...
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.Technical fees arising in a Contracting State which are derived...
3.The term “technical fees” as used in this Article means...
4.The provisions of paragraphs (1) and (2) of this Article...
5.Technical fees shall be deemed to arise in a Contracting...
6.Where, by reason of a special relationship between the payer...
Directors' fees and other similar payments derived by a resident...
Provided that relief from United Kingdom tax shall not be...
Article 27 Members of diplomatic or permanent missions and consular posts
This Convention shall remain in force until terminated by one...
In witness whereof the undersigned, duly authorised thereto by their...