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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.The term “permanent establishment” also includes a building site or...
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...
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 derived by a resident of a Contracting State from...
7.Gains from the alienation of any property other than that...
Directors' fees and other similar payments derived by a resident...
Article 18 PENSIONS, ANNUITIES, ALIMONY AND SOCIAL SECURITY PAYMENTS
Payments which a student or business apprentice who is or...
Article 23 MISCELLANEOUS RULES APPLICABLE TO CERTAIN OFFSHORE ACTIVITIES
1.The provisions of this Article shall apply notwithstanding any other...
2.In this Article the term “offshore activities” means activities which...
3.An enterprise of a Contracting State which carries on offshore...
4.Subject to the provisions of paragraph (5) of this Article,...
5.The provisions of paragraphs (3) and (4) of this Article...
6.Profits derived by a resident of a Contracting State from...
7.(a) Subject to sub-paragraph (b) of this paragraph, salaries, wages...
8.Gains derived by a resident of a Contracting State from...
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.Nothing contained in this Article shall be construed as obliging...
5.Enterprises of a Contracting State, the capital of which is...
Article 32 MEMBERS OF DIPLOMATIC OR PERMANENT MISSIONS AND CONSULAR POSTS
Nothing in this Convention shall affect the fiscal privileges of...
(1) This Convention shall remain in force until terminated by...
In witness whereof the undersigned, duly authorised thereto by their...
Done in duplicate at London this 12th day of October...
London
12th October 2000
Excellency
I have the honour to refer to the Convention between...
Where, under the terms of paragraph (6) of Article 10,...
If the foregoing proposal is acceptable to the Goverenment of...
I avail myself of this opportunity to extend to Your...
Stephen C Timms
London
12th October 2000
Excellency
I have the honour to acknowledge receipt of Your Excellency’s...
The foregoing proposals being acceptable to the Government of the...
I take this opportunity to renew to Your Excellency the...
Tarald O Brautaset
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