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.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...
Article 6 Limitation of relief
Where under any provision of this Convention any income or...
1.The profits of an enterprise of a Contracting State shall...
2.Subject to the provisions of paragraph (3), where an enterprise...
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...
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...
7.Any provision in the laws of either Contracting State relating...
10.Notwithstanding the provisions of paragraph (2) of this Article, interest...
11.Notwithstanding the provisions of Article 8 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.Technical fees arising in a Contracting State and paid to...
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...
Article 22 Students and trainees
Payments which a student, apprentice or business trainee who is,...
Items of income beneficially owned by a resident of a...
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 Article 10, paragraph (6) of...
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
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 by their...
Done in duplicate at Georgetown this 31st day of August...
Georgetown
31st August 1992
Excellency
I have the honour to refer to the Convention between...
If the foregoing proposal is acceptable to the Government of...
I avail myself of this opportunity to extend to Your...
Robert D. Gordon
His Excellency the High
Commissioner of the
United Kingdom of
Great Britain and
Northern Ireland
The foregoing proposal being acceptable to the Government of Guyana,...