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.Notwithstanding the preceding provisions of this Article, the term “permanent...
4.An enterprise of a Contracting State shall be deemed to...
5.A person (other than a broker, general commission agent or...
6.An enterprise of a Contracting State shall not be deemed...
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 the profits include items of income which are dealt...
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...
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 derived from one of the Contracting States by...
2.The term “technical fees” as used in this Article means...
3.The provisions of paragraph (1) of this Article shall not...
4.Technical fees shall be deemed to arise in a Contracting...
5.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 similar payments derived by a resident of...
ARTICLE 22 Students and trainees
An individual who is or was 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 paragraph (1) of Article 9,...
4.Enterprises of a Contracting State, the capital of which is...
6.The provisions of this Article shall apply to the taxes...
ARTICLE 29 Members of diplomatic or permanent missions and consular posts
This Agreement shall remain in effect indefinitely, but either Contracting...
In witness whereof the undersigned, duly authorised thereto have signed...
Done in duplicate at Kuala Lumpur this 10th day of...
For the Government of the United Kingdom of Great Britain...
Excellency Kuala Lumpur 10th December 1996
I have the honour to refer to the Agreement between...
the provisions of this Agreement shall not apply to persons...
If the foregoing proposals are acceptable to the Government of...
I avail myself of this opportunity to extend to your...
I have the honour to acknowledge receipt of Your Excellency’s...
The foregoing proposals being acceptable to the Government of Malaysia,...