2.It is hereby declared— (a) that the arrangements specified in...
The Government of the United Kingdom of Great Britain and...
Desiring to conclude an Agreement for the avoidance of double...
Have agreed as follows:
This Agreement shall apply to persons who are residents of...
Article 5 Permanent establishment
1.For the purposes of this Agreement, 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...
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.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...
8.Notwithstanding the provisions of paragraph (2) of this Article, interest...
9.Notwithstanding the provisions of Article 7 of this Agreement 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.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 a resident 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 business apprentice who is or...
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 paragraph (1) of Article 9,...
4.Enterprises of a Contracting State, the capital of which is...
5.Nothing contained in this Article shall be construed as obliging...
Article 26 Members of diplomatic or permanent missions and consular posts
Nothing in this Agreement shall affect any fiscal privileges accorded...
Each of the Contracting States shall notify to the other...
This Agreement shall remain in force until terminated by one...
Mr Alastair Goodlad
Minister of State for Foreign and Commonwealth Affairs
Foreign and Commonwealth Office
LONDON
9th April 1994
Excellency,
I have the honour to refer to the Agreement between...
If the foregoing proposals are acceptable to the Government of...
I take this opportunity to renew to your Excellency the...
For the Government of the Socialist Republic of Vietnam
Ho Te
Minister of Finance
His Excellency Mr Ho Te
Minister of Finance
8 Phan Huy Chu
Hanoi
9th April 1994
Excellency,
In am in receipt of your Note dated 9th April...
The foregoing proposals being acceptable to the Government of the...
I take this opportunity to renew to Your Excellency the...
For the Government of the United Kingdom of Great Britain...
Alastair Goodlad
Minister of State for Foreign and Commonwealth Affairs