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 new Convention for the avoidance of...
Have agreed as follows:
Article 5 Permanent establishment
1.For the purposes of this Convention, the term “permanent establishment”...
2.The term “permanent establishment” shall include especially:
3.The term “permanent establishment” shall not be deemed to include:...
5.An enterprise of a Contracting State shall not be deemed...
7.For the purposes of this Article the term “control”, in...
1.The profits of an enterprise of a Contracting State shall...
2.Where an enterprise of a Contracting State carries on business...
3.Where a permanent establishment takes an active part in negotiating,...
4.Insofar as it has been customary in a Contracting State...
7.Paragraph (5) of this Article shall not apply to amounts,...
8.No profits shall be attributed to a permanent establishment by...
9.Where profits include items of income which are dealt with...
1.Income of an enterprise of a Contracting State from the...
2.The provisions of paragraph (1) of this Article shall not...
3.For the purposes of this Article, income from the operation...
4.Notwithstanding the provisions of Article 7 (Business profits) of this...
5.The provisions of this Article shall apply also to income...
6.Gains derived by an enterprise of a Contracting State from...
2.However, such interest may also be taxed in the Contracting...
3.Notwithstanding the provisions of paragraph (2) of this Article:
4.Notwithstanding the provisions of Article 7 of this Convention and...
5.The term “interest” as used in this Article means income...
6.The provisions of paragraphs (1), (2) and (3)(a) of this...
7.Interest shall be deemed to arise in a Contracting State...
8.Where, owing to a special relationship between the payer and...
9.Any provision in the laws of either Contracting State relating...
Article 13 Royalties and fees for technical services
1.Royalties and fees for technical services arising in a Contracting...
2.However, such royalties and fees for technical services may also...
3.For the purposes of this Article, the term “royalties” means:...
5.The definitions of fees for technical services in paragraph (4)...
6.The provisions of paragraphs (1) and (2) of this Article...
7.Royalties and fees for technical services shall be deemed to...
8.Where, owing to a special relationship between the payer and...
Except as provided in Article 8 (Air transport) and 9...
Directors' fees and similar payments derived by a resident of...
1.The nationals of a Contracting State shall not be subjected...
2.The taxation on a permanent establishment which an enterprise of...
3.Nothing contained in this Article shall be construed as obliging...
4.Enterprises of a Contracting State, the capital of which is...
5.In this Article, the term “taxation” means taxes which are...
This Convention shall remain in force until terminated by one...
In witness whereof the undersigned, duly authorised thereto by their...
Done on this 25th day of January 1993, in New...
For the Government of the United Kingdom of Great Britain...
Nicholas Fenn
For the Government of the Republic of India:
S. Ramamurti
Your Excellency
New Delhi
25th January 1993
I have the honour to refer to the Convention between...
If the foregoing proposal is acceptable to the Government of...
Nicholas Fenn
His Excellency the High Commissioner of the United Kingdom of...
Your Excellency
New Delhi
25th January 1993
I have the honour to acknowledge receipt of Your Excellency’s...
In reply, I have the honour to state that the...
I avail myself of this opportunity to renew to Your...
S Ramamurti
His Excellency the Chairman of the Central Board of Direct...