CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED …

CONVENTION BETWEENTHE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THEGOVERNMENT OF THE UNITED KINGDOMOF GREAT BRITAIN AND NORTHERN IRELANDFOR THE AVOIDANCE OF DOUBLE TAXATION AND THEPREVENTION OF FISCAL EVASIONWITH RESPECT TO TAXES ON INCOME AND ON CAPITAL GAINSThe GOVERNMENT of the UNITED States of America and the GOVERNMENT of the UnitedKingdom of Great Britain and Northern Ireland,Desiring to conclude a new CONVENTION for the avoidance of double taxation and theprevention of fiscal evasion with respect to taxes on income and on capital gains,Have agreed as follows:2 ARTICLE 1 General Scope1. Except as specifically provided herein, this CONVENTION is applicable only to personswho are residents of one or both of the Contracting This CONVENTION shall not restrict in any manner any benefit now or hereafteraccorded:a) by the laws of either Contracting State; orb) by any other agreement BETWEEN the Contracting ) Notwithstanding the provisions of sub-paragraph b) of paragraph 2 of thisArticle:(i) any question arising as to the interpretation or application of thisConvention and, in particular, whether a taxation measure is within the scope ofthis CONVENTION , shall be determined excl

b) the term “company” means any body corporate or any entity that is treated as a body corporate for tax purposes; c) the term “enterprise” applies to the carrying on of any business; d) the term “business” includes the performance of professional services and of other activities of an independent character;

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