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The Double Taxation Relief (Taxes on Income) (The United States of America) Order 2002
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- UK Statutory Instruments
- 2002 No. 2848
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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 new Convention for the avoidance of...
Have agreed as follows:
1.Except as specifically provided herein, this Convention is applicable only...
2.This Convention shall not restrict in any manner any benefit...
3.(a) Notwithstanding the provisions of sub-paragraph (b) of paragraph 2...
4.Notwithstanding any provision of this Convention except paragraph 5 of...
5.The provisions of paragraph 4 of this Article shall not...
6.A former citizen or long-term resident whose loss of citizenship...
7.Where under any provision of this Convention income or gains...
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.A building site or construction or installation project constitutes a...
4.Notwithstanding the preceding provisions of this Article, the term “permanent...
5.Notwithstanding the provisions of paragraphs 1 and 2 of this...
1.The business profits of an enterprise of a Contracting State...
2.Subject to the provisions of paragraph 3 of this Article,...
3.In determining the business profits of a permanent establishment, there...
4.For the purposes of the preceding paragraphs, the profits to...
5.The United States excise tax on insurance policies issued by...
6.Where business profits include items of income that are dealt...
7.In applying this Article, paragraph 5 of Article 10 (Dividends),...
2.However, such dividends may also be taxed in the Contracting...
3.Notwithstanding the provisions of paragraph 2 of this Article, dividends...
4.Sub-paragraph (a) of paragraph 2 and paragraph 3 of this...
5.The previous provisions of this Article shall not apply if...
6.A Contracting State may not impose any tax on dividends...
9.The provisions of this Article shall not apply in respect...
10.For the purposes of this Article: (a) the term “dividends”...
1.Interest arising in a Contracting State and beneficially owned by...
2.The term “interest” as used in this Article means income...
3.The provisions of paragraph 1 of this Article shall not...
4.Where, by reason of a special relationship between the payer...
5.(a) Notwithstanding the provisions of paragraph 1 of this Article,...
6.Notwithstanding the provisions of paragraph 1 of this Article, a...
7.The provisions of this Article shall not apply in respect...
1.Gains derived by a resident of a Contracting State that...
2.For the purposes of this Article the term “real property...
3.Gains from the alienation of property (other than real property)...
4.Gains derived by an enterprise of a Contracting State from...
5.Gains from the alienation of any property other than property...
6.The provisions of paragraph 5 of this Article shall not...
Directors' fees and other similar payments derived by a resident...
Article 17 Pensions, social security, annuities, alimony, and child support
1.(a) Pensions and other similar remuneration beneficially owned by a...
2.Notwithstanding the provisions of paragraph 1 of this Article, a...
3.Notwithstanding the provisions of paragraph 1 of this Article, payments...
4.Any annuity derived and beneficially owned by an individual (“the...
5.Periodic payments, made pursuant to a written separation agreement or...
Payments received by a student or business apprentice who is,...
Article 23 Limitation on benefits
1.Except as otherwise provided in this Article, a resident of...
2.A resident of a Contracting State is a qualified person...
4.(a) Notwithstanding that a resident of a Contracting State may...
5.Notwithstanding the preceding provisions of this Article, if a company...
7.For the purposes of this Article the following rules and...
Article 24 Relief from double taxation
1.In accordance with the provisions and subject to the limitations...
2.For the purposes of applying paragraph 1 of this Article,...
3.Notwithstanding the provisions of paragraph 1 of this Article, the...
5.For the purposes of paragraph 4 of this Article, profits,...
6.Where the United States taxes, in accordance with paragraph 4...
1.Nationals of a Contracting State shall not be subjected in...
2.The taxation on a permanent establishment that an enterprise of...
3.Except where the provisions of the second sentence of paragraph...
4.Enterprises of a Contracting State, the capital of which is...
5.Nothing in this Article shall be construed as obliging either...
6.Nothing in this Article shall be construed as preventing either...
7.The provisions of this Article shall, notwithstanding the provisions of...
Article 27 Exchange of information and administrative assistance
1.The competent authorities of the Contracting States shall exchange such...
2.If information is requested by a Contracting State in accordance...
4.If specifically requested by the competent authority of a Contracting...
5.Each of the Contracting States shall endeavour to collect on...
6.The competent authority of a Contracting State intending to send...
7.The competent authorities of the Contracting States shall consult with...
Article 28 Diplomatic agents and consular officers
Nothing in this Convention shall affect the fiscal privileges of...
1.This Convention shall be subject to ratification in accordance with...
2.This Convention shall enter into force upon the exchange of...
3.The Convention between the Government of the United States of...
4.Notwithstanding the entry into force of this Convention, an individual...
5.Nothwithstanding the entry into force of this Convention, an individual...
This Convention shall remain in force until terminated by a...
IN WITNESS WHEREOF, the undersigned, being duly authorised thereto by...
DONE at London in duplicate, this 24th day of July,...
FOR THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN...
Gordon Brown
FOR THE GOVERNMENT OF THE UNITED STATES OF AMERICA
Paul H O'Neill
The Government of the United Kingdom of Great Britain and...
Desiring to conclude a Protocol to amend the Convention for...
Have agreed as follows:
Paragraph 5 of Article 1 of the Convention shall be...
Paragraph 4 of Article 10 of the Convention shall be...
The following new Article 20A shall be inserted: Article 20A...
Sub-paragraph (d) of paragraph 7 of Article 23 of the...
This Protocol shall remain in force as long as the...
IN WITNESS WHEREOF, the undersigned, being duly authorised thereto by...
DONE at Washington in duplicate this 19th day of July...
FOR THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN...
T. W. Scholar
FOR THE GOVERNMENT OF THE UNITED STATES OF AMERICA
Charles P. Ries
London
24 July 2001
Excellency:
I have the honour to refer to the Convention between...
With reference to paragraph 3 of Article 1 (General Scope):
With reference to paragraph 6 of Article 1 (General Scope):
With reference to paragraph 8 of Article 1 (General Scope):
It is further understood that, where, by virtue of the...
It is further understood that, in applying the paragraph, the...
It is further understood that, in applying the paragraph, a...
With reference to Article 2 (Taxes Covered):
With reference to sub-paragraph (o) of paragraph 1 of Article 3 (General Definitions):
With reference to Article 7 (Business Profits):
With reference to paragraph 2 of Article 8 (Shipping and Air Transport):
With reference to Article 9 (Associated Enterprises), paragraph 4 of Article 11 (Interest) and paragraph 4 of Article 12 (Royalties):
With reference to paragraph 7 of Article 10 (Dividends):
With reference to Article 14 (Income from Employment):
It is further understood that where an employee:
With the aim of ensuring that no unrelieved double taxation...
With reference to paragraph 1 of Article 17 (Pensions, Social Security, Annuities, Alimony, and Child Support):
With reference to sub-paragraph (b) of paragraph 3 and sub-paragraph (d) of paragraph 5 of Article 18 (Pension Schemes):
With reference to paragraph 1 of Article 22 (Other Income):
With reference to Article 23 (Limitation on Benefits):
With reference to paragraph 4 of Article 23 (Limitation on Benefits):
It is understood that an item of income, profit or...
With reference to paragraph 6 of Article 23 (Limitation on Benefits):
Paragraph 6 of Article 23 requires the competent authority of...
If the competent authority is satisfied that these changed circumstances...
With reference to sub-paragraph (e) of paragraph 7 of Article 23 (Limitation on Benefits):
With reference to Article 24 (Relief from Double Taxation):
In the case where the same item of income, profit...
It is further understood that paragraphs 2 and 5 of...
With reference to paragraphs 1 and 4 of Article 24 (Relief from Double Taxation):
With reference to paragraph 2 of Article 26 (Mutual Agreement Procedure):
With reference to paragraph 3 of Article 26 (Mutual Agreement Procedure):
With reference to Article 27 (Exchange of Information and Administrative Assistance):
With reference to Article 29 (Entry into Force):
In General:
Notwithstanding the preceding paragraph, either Government may at any time...
If the foregoing proposals are acceptable to the Government of...
I avail myself of this opportunity to extend to Your...
R D Wilkinson
Director Americas Foreign and Commonwealth Office, London
The foregoing proposals being acceptable to the Government of the...
Please accept the renewed assurance of my highest consideration.
Ambassador, The Honourable William S. Farish, The American Ambassador to...
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