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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.A building site, a construction, assembly or installation project constitutes...
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.No profits shall be attributed to a permanent establishment by...
5.For the purposes of the preceding paragraphs, the profits to...
6.Where profits include items of income or capital gains which...
2.However, such interest may also be taxed in the Contracting...
3.Notwithstanding the provisions of paragraph (2) interest arising in a...
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...
8.Any provisions in the laws of either Contracting State relating...
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 an enterprise 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 an apprentice or trainee, who...
Where, under any provision of this Convention, a partnership is...
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 29 Members of diplomatic or permanent missions and consular posts
Nothing in this Convention shall affect the fiscal privileges accorded...
The Governments of each of the Contracting States shall notify...
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 12th day of May...
London
12th May 1994
Excellency
I have the honour to refer to the Convention between...
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