SCHEDULEFourth Protocol Amending the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income Signed at London on 22 May 1968, as Modified by the Protocols Signed at London on 10 February 1971, 14 May 1973 and 12 June 1986
Article 15
Paragraph (b) of Article 24 of the Convention shall be deleted and replaced by the following:
b
In the case of France:
i
income other than that mentioned in sub-paragraph (ii) below shall be exempt from the French taxes mentioned in paragraph (1) of Article 1 while the income is, under the Convention, taxable in the United Kingdom;
ii
as regards income mentioned in Articles 9 and 17 which has borne United Kingdom tax in accordance with the provisions of these Articles, France shall allow to a resident of France receiving such income from the United Kingdom a tax credit corresponding to the amount of tax levied in the United Kingdom. Such tax credit, not exceeding the amount of French tax levied on such income, shall be allowed against taxes mentioned in sub-paragraph (1)(b) of Article 1 of this Convention, in the bases of which such income is included;
iii
notwithstanding the provisions of sub-paragraphs (i) and (ii) French tax may be computed on income chargeable in France by virtue of this Convention at the rate appropriate to the total of the income chargeable in accordance with French law.