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.An enterprise shall be deemed to have a permanent establishment...
4.(a) The duration of activities under subparagraph (a) of paragraph...
5.Notwithstanding the preceding provisions of this Article, an enterprise shall...
6.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.Nothing in this Article shall affect the application of any...
5.No profits shall be attributed to a permanent establishment by...
6.Where profits include items of income or gains which are...
7.Nothing in this Article shall affect the operation of any...
1.Interest arising in a Contracting State and beneficially owned by...
2.However, that interest may also be taxed in the Contracting...
3.Notwithstanding paragraph 2, interest arising in a Contracting State and...
4.Notwithstanding paragraph 3, interest referred to in subparagraph (b) of...
5.The term “interest” as used in this Article means income...
6.The provisions of paragraphs 1 and 2, subparagraph (b) of...
7.Interest shall be deemed to arise in a Contracting State...
8.Where, by reason of a special relationship between the payer...
1.Royalties arising in a Contracting State and beneficially owned by...
2.However, those royalties may also be taxed in the Contracting...
3.The term “royalties” in this Article means payments or credits,...
5.Royalties shall be deemed to arise in a Contracting State...
6.Where, by reason of a special relationship between the payer...
Where a student, who is a resident of a Contracting...
Income or gains derived by a resident of the United...
Where a partnership is treated as a taxable unit under...
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...
7.The provisions of this Article shall apply to the taxes...
ARTICLE 28 Members of diplomatic missions or permanent missions and consular posts
Nothing in this Convention shall affect the fiscal privileges of...
This Convention shall remain in force until terminated by one...
IN WITNESS WHEREOF the undersigned, duly authorised thereto by their...
DONE in duplicate at Canberra this 21st day of August...
No LGB 03/170
The Department of Foreign Affairs and Trade presents its compliments...
The Department has the honour to make the following proposals...
If the foregoing proposals are acceptable to the Government of...
The Department of Foreign Affairs and Trade avails itself of...
CANBERRA
21st August 2003
No 41/03
The British High Commission to Australia presents its compliments to...
The High Commission has the honour to advise that the...
The British High Commission to Australia avails itself of this...
CANBERRA
21st August 2003