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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.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 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.Insofar as it has been customary in a Contracting State...
5.No profits shall be attributed to a permanent establishment by...
6.For the purposes of the preceding paragraphs, the profits to...
7.Where profits include items of income or capital gains which...
2.The term “interest” as used in this Article means income...
3.The provisions of paragraph (1) of this Article shall not...
4.Interest shall be deemed to arise in a Contracting State...
5.Where, by reason of a special relationship between the payer...
6.Any provision in the laws of either Contracting State relating...
1.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 other similar payments derived by a resident...
Payments which a student or business apprentice who is or...
Where, under any provision of this Convention, a partnership or...
1.Nationals of a Contracting State shall not be subjected in...
2.Stateless persons who are residents of either Contracting State shall...
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 Contracting State, the capital of which is...
6.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 or permanent missions and consular posts
Nothing in this Convention shall affect any fiscal privileges accorded...
This Convention shall remain in force until terminated by one...
In witness whereof the undersigned, duly authorised thereto, have signed...
Done in duplicate at London this 10th day of February...
For the Government of the United Kingdom of Great Britain...
For the Government of Ukraine:
Norman Lamont
Hryhory P'yatachenko
London
10th February 1993
Excellency
I have the honour to refer to the Convention between...
1.Interest payable by a permanent establishment of a resident of...
2.Wages, salaries and other remuneration for personal services payable by...
3.Interest payable by a company or other taxable entity which...
4.Wages, salaries and other remuneration for personal services payable by...
5.Withholding Tax Each Contracting State shall endeavour to establish procedures...
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