This agreement applies for periods before the new comprehensive
agreement has effect (see DT3850).Nationals of a Contracting State
shall not be subjected in the other Contracting State to any
taxation or any requirement connected therewith which is other or
more burdensome than the taxation and connected requirements to
which nationals of that other State in the same circumstances are
or may be subjected.
The taxation on a permanent establishment which an enterprise
of a Contracting State has in the other Contracting State shall not
be less favourably levied in that other State than the taxation
levied on enterprises of that other State carrying on the same
activities.
Enterprises of a Contracting State, the capital of which is
wholly or partly owned or controlled, directly or indirectly, by
one or more residents of the other Contracting State, shall not be
subjected in the first-mentioned Contracting State to any taxation
or any requirement connected therewith which is other or more
burdensome than the taxation and connected requirements to which
other similar enterprises of that first-mentioned State are or may
be subjected.
Nothing contained in this Article shall be construed as
obliging either Contracting State to grant to individuals not
resident in that State any of the personal allowances, reliefs and
reductions for tax purposes which are granted to individuals so
resident, nor as obliging the United Kingdom to grant to a company
which is a resident of Botswana a greater relief from United
Kingdom income tax chargeable on dividends received from a company
which is a resident of the United Kingdom than the relief to which
the first-mentioned company may be entitled under the provisions of
Article 10 of this Agreement.
