DT3661 - DT: Bolivia: double taxation agreement, SI 95 No.2707, Exchange of Notes
- The Contracting States declare:
This Convention shall not be opposed to the respective tax systems of the Contracting States and in particular to the Bolivian tax system based on source and to the United Kingdom tax system based on residence and worldwide income.
- With respect to Article 7:
- There may only be attributed to a building site or construction
or installation project in the Contracting State in which the
permanent establishment is situated, the profits which are derived
from such activities. Profits derived as a result of supplies of
merchandise from the main permanent establishment or from another
permanent establishment of the enterprise or a third person in
connection with such activities or realised independently of such
activities, shall not be attributed to the building site or
construction or installation project;
- Income derived as a result of planning, design, construction or research activities and technical services carried out in a Contracting State by a resident of that State in connection with a permanent establishment maintained in the other Contracting State shall not be attributed to that establishment.
- With respect to Article 11:
It is assumed that the commission paid by a resident of Bolivia to a bank or other credit institution in relation to services provided by the bank or credit institution shall be regarded as interest in accordance with paragraph (3) of Article 11.
- With respect to Articles 10, 11 and 12:
- If the rates under the respective national law are lower than
the rates determined in the Convention, the lower rates of the
national legislation will apply, without affecting any future
rulings.
- If Bolivia has agreed in a Convention for the elimination of
double taxation in force between it and any other member country of
the Organisation for Economic Co-operation and Development to apply
a lower rate of taxation to dividends, interest or royalties than
that specified in Articles 10, 11 and 12 respectively, that lower
rate shall be substituted for the rate specified in those Articles
with effect from the date when that Convention enters into force.
