2.It is hereby declared — (a) that the arrangements specified...
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.Notwithstanding the preceding provisions of this Article, the term “permanent...
4.Notwithstanding the provisions of paragraphs (1) and (2) of this...
CHAPTER III TAXATION OF INCOME
(1) The profits of an enterprise of a Contracting State...
Article 8 Shipping and air transport
(1) Profits derived by a resident of a Contracting State...
Article 9 Associated enterprises
(1) Where: (a) an enterprise of a Contracting State participates...
2.However, such interest may also be taxed in the Contracting...
3.Notwithstanding the provisions of paragraph (2) of this Article, interest...
4.Notwithstanding the provisions of Article 7 of this Convention and...
5.The term “interest” as used in this Article means income...
7.Interest shall be deemed to arise in a Contracting State...
8.Where, by reason of a special relationship between the payer...
10.For the purposes of this Article the following residents of...
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...
8.For the purposes of this Article the following residents of...
(1) Gains derived by a resident of a Contracting State...
Directors' fees and other similar payments derived by a resident...
Article 17 Artistes and athletes
(1) Notwithstanding the provisions of Article s 14 and 15...
(1)(a) Remuneration, other than a pension, paid by a Contracting...
Payments which a student or business apprentice who is or...
CHAPTER IV METHODS FOR THE ELIMINATION OF DOUBLE TAXATION
Article 22 Elimination of double taxation
(1) Subject to the provisions of the law of the...
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...
6.The provisions of this Article shall apply to the taxes...
Where, under any provision of this Convention, a partnership is...
Article 27 Members of diplomatic or permanent missions and consular posts
Nothing in this Convention shall affect any fiscal privileges accorded...
This Convention shall remain in force indefinitely until terminated by...
Done in duplicate at Caracas this 11th day of March,...
Your Excellency
I have the honour to refer to the Convention between...
If the following proposal is acceptable to the Government of...
I avail myself of this opportunity to extend to Your...
Your Excellency
I am in receipt of your note dated 11th March...
The foregoing proposal being acceptable to the Government of the...
I take this opportunity to renew to Your Excellency the...