Transcription of DEPARTMENT OF THE TREASURY THE GOVERNMENT OF …
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DEPARTMENT OF THE TREASURY THE GOVERNMENT OF …
DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL GAINS This is a technical explanation of the Convention between the United States and the United Kingdom of Great Britain and Northern Ireland, signed on July 24, 2001 (the Convention ), as amended by the Protocol between the United States and the United Kingdom of Great Britain and Northern Ireland, signed on July 22, 2002 (the "Protocol"). References are made to the Convention between the GOVERNMENT of the United States of America and the GOVERNMENT of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed on December 31, 1975, as amended by Protocols signed on August 26, 1976, March 31, 1977, and March 15, 1979 (the prior Convention ).
("MFN") obligations undertaken by the Contracting States pursuant to the GATS shall apply to a taxation measure, unless the competent authorities otherwise agree. The Convention does not include an additional limitation on the application of other agreements that is included in the U.S. Model. The U.S. Model provision states that national-
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