Replaced by new DTA, which applies in UK from 1st April 2003 for
CT, 6th April 2003 for IT and 1st January 2004 for PRT. For US
withholding taxes it applies from 1st May 2003 and for other US
taxes from 1st January 2004. See DT19939I.
(1)
(a) Remuneration, other than a pension, paid by a
Contracting State to any individual in respect of services rendered
to that State shall be taxable only in that State.
(b) however, such remuneration shall be taxable only in the
other Contracting State if the services are rendered in that State
and the recipient is a resident and a national of that State.
(2)
(a) Any pension paid by a Contracting State or a political
subdivision or a local authority thereof to any individual in
respect of services rendered to that State or subdivision or local
authority thereof shall be taxable only in that State.
(b) However, such pension shall be taxable only in the other
Contracting State if the recipient is a national of and a resident
of that State.
(3) The provisions of Articles 14 (Independent personal
services) 15 (Dependent personal services), 17 (Artistes and
athletes), and 18 (Pensions), as the case may be, shall apply to
remuneration and pensions in respect of services rendered in
connection with any business carried on by or on behalf of one of
the Contracting States or a political subdivision or a local
authority thereof.
