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2.It is hereby declared— (a) that the arrangements specified in...
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...
5.Notwithstanding the preceding provisions of this Article, the term “permanent...
6.Notwithstanding the provisions of paragraphs (1) and (2) of this...
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 territory...
3.The term “interest” as used in this Article means income...
5.Where, by reason of a special relationship between the payer...
8.Notwithstanding the provisions of paragraph (2) of this Article, interest...
9.For the purposes of paragraph (8)(b) of this Article the...
1.Royalties arising in a territory and paid to a resident...
2.However, those royalties may also be taxed in the territory...
3.The term “royalties” as used in this Article means payments...
4.The provisions of paragraph (1) and (2) of this Article...
6.Where, by reason of a special relationship between the payer...
Directors' fees and other similar payments derived by a resident...
(a) Salaries, wages and other similar remuneration, other than a...
Where a student, who is a resident of a territory...
1.Citizens or nationals of a territory shall not be subjected...
2.A legal person, partnership or association deriving its status as...
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 territory, the capital of which is wholly...
6.Nothing contained in this Article shall be construed as obliging...
7.The provisions of this Article shall apply to the taxes...
The BTCO and the TRO shall each notify to the...
This Agreement shall remain in force until terminated by the...
In witness whereof the undersigned, duly authorised thereto, have signed...
Done in duplicate at London this 8th day of April...
For the British Trade and For the Taipei Cultural Office,...
David Coates
Director-General, British Trade and Cultural Office, Taipei
For the Taipei Representative Office in the United Kingdom
Wen-hua Tzen
Representative, Taipei Representative Office in the United Kingdom
Having regard to the Agreement for the avoidance of double...
Have agreed that the following provisions shall form an integral...
With respect to the territory in which the taxation law...
The remuneration, pensions, or annuities of staff of the Taipei...
In witness whereof the undersigned have signed this Annex.
Done in duplicate at London this 8th day of April...
For the British Trade and For the Taipei Cultural Office,...
David Coates
Director-General, British Trade and Cultural Office, Taipei
For the Taipei Representative Office in the United Kingdom
Wen-hua Tzen
Representative, Taipei Representative Office in the United Kingdom
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