【法规名称】
【颁布时间】 2002-04-08
【法规编号】 43456 什么是编号？
【正 文】
第7页 AGREEMENT BETWEEN THE TAIPEI REPRESENTATIVE OFFICE IN THE UNITED KINGDOM AND THE BRITISH TRADE AND CULTURAL OFFICE, TAIPEI FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL GAINS
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[接上页] fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employ-er who is not a resident of the other territory; and (c) the remuneration is not borne by a permanent establishm-ent or a fixed base which the employer has in the other territory. (3) Notwithstanding the preceding provisions of this Article, r-emuneration derived in respect of an employment exercised a-board a ship or aircraft operated in international trafficmay be taxed in the territory of which the enterprise opera-ting the ship or aircraft is a resident. ARTICLE 16 Directors' fees Directors' fees and other similar payments derived by a residentof a territory in his capacity as a member of the board of dire-ctors of a company which is a resident of the other territory m-ay be taxed in that other territory. ARTICLE 17 Artistes and sportsmen (1) Notwithstanding the provisions of Articles 14 and 15 of thisAgreement, income derived by a resident of a territory as anentertainer, such as a theatre, motion picture, radio or te-levision artiste, or a musician, or as a sportsman, from hispersonal activities as such exercised in the other territory, may be taxed in that other territory. (2) Where income in respect of personal activities exercised byan entertainer or a sportsman in his copacity as such accru-es not to the entertainer or sportsman himself but to anoth-er person, that income may, notwithstanding the provisionsof Articles 7, 14 and 15 of this Agreement, be taxed in theterritory in which the activities of the entertainer or spo-rtsman are exercised. (3) The provisions of paragraphs (1) and (2) of this Article sh-all not apply to income derived by entertainers or sportsmenwho are residents of a territory from their personal activi-ties as entertainers or sportsmen exercised in the other te-rritory if their visit to that other territory is wholly orsubstantially supported from the public funds of the first-mentioned territory. In such a case, the income shall be ta-xable only in the territory of which the entertainer or spo-rtsman, as the case may be, is a resident. ARTICLE 18 Pensions and annuities (1) Subject to the provisions of paragraph (2) of Article 19 ofthis Agreement: (a) pensions and other similar remuneration paid in conside-ration of past employment, and (b) any annuity paid, to an individual who is a resident ofa territory, and is subject to tax in respect thereof in that territory, shall be taxable only in that territory. (2) The term "annuity" means a stated sum payable to an individ-ual periodically at stated times during his life or during aspecified or ascertainable period of time under an obligati-on to make the payments in return for adequate and full con-sideration in money or money's worth. (3) Notwithstanding the provisions of paragraph (1) of this Art-icle, a lump-sum payment beneficially owned by a resident ofa territory from a pension scheme established in the otherterritory shall be taxable only in that other territory. ARTICLE 19 Public service (1) (a) Salaries, wages and other similar remuneration, other t-han a pension or annuity, paid by an authority administ- ering a territory or a subdivision thereof, or by a loc- al authority of that territory to an individual in resp- ect of services rendered in the discharge of public or administrative functions on behalf of such an authority shall be taxable only in that territory. (b) Notwithstanding the provisions of sub-paragraph (a) ofthis paragraph, such salaries, wages and other similar remuneration shall be taxable only in the other territo- ry if the services are rendered in that territory and t- he individual is a resident of that territory who: (i) is a citizen or national Of that territory; or (ii) did not become a resident of that territory solely f-or the purpose of rendering the services. (2) (a) Any pension or annuity paid by, or out of funds createdby, a teiritory or a political subdivision or a local a- uthority thereof to an individual in respect of services rendered to that territory or subdivision or authority shall be taxable only in that territory. (b) Notwithstanding the provisions Of sub-paragraph (a) ofthis paragraph, such pension orannuity shall be taxable only in the other territory if the individual is a resi- dent of and a citizen or national of, that territory. (3) The provisions of Articles 15,16, 17 and l8 of this Agreeme-nt shall apply to salaries, wages and other similar remuner-ation, and to pensions or annuities, in respect of servicesrendered in connection with abusiness carried on by any aut-hority refe-rred to in paragraph (1) of this Article. ARTICLE 20 Students Where a student, who is a resident of a territory or whowas a r-esident of that territory immediately before visiting the otherterritory anti whet is temporarily present in that. other terri-tciry solely for the purpose of the student's education, receiv-es payments from sources outside that other territory for the p-urpose of the student's maintenance or education, those paymentsshall be exempt from tax in that other territory. |
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