of October 15, 1993
About avoidance of double taxation and prevention of tax avoidance on the income and increase in capital value
Government of the Republic of Uzbekistan and Government of the United Kingdom of Great Britain and Northern Ireland,
Intending to sign the Convention on elimination of double taxation concerning taxes on the income and increase in capital value without creation of opportunities for not taxation or decrease in the taxation by evasion or avoidance (including the opportunities promoting provision of the privileges provided by the Convention for indirect benefit of residents of the third countries);
agreed as follows:
(1) This Convention is applied to persons who are residents of one or both Contracting States.
(2) for the purposes of this Convention the income or increase in value received by the company or organization or through the company or organization which is considered as fully or partially financially transparent according to the tax legislation of any of Contracting States is considered the income or increase in value of resident of the Contracting State, but only in that degree in what this income or increase in value is considered for the purposes of the taxation by this State as the income of resident of this State.
(3) This Convention does not belong to the taxation the Contracting State of the residents, except as specified provisions of privileges according to Item (3) Articles 7, spunkty (2) Article 9 and Articles 19, of 20, of 22, of 25, 26 and 28.
1. This Convention extends to taxes on the income and the increase in capital value levied on behalf of the Contracting State or local authorities irrespective of method of their collection.
2. All taxes levied from total income or on part of the income, including taxes on the income from alienation of personal or real estate and taxes on the total amounts of the salary or salaries paid by the companies belong to taxes on the income and increase in capital value.
(3) the Existing taxes to which this Convention extends are in particular:
(a) in relation to Uzbekistan:
(i) income tax of legal entities;
(ii) income tax; and
(iii) property tax;
(further referred to as as "taxes of Uzbekistan");
(b) in relation to the United Kingdom:
(i) tax on the income;
(ii) corporate tax; and
(iii) capital gain tax;
(further referred to as as "taxes of the United Kingdom").
4. This Convention will be applied also to any identical or in essence to similar taxes which will be levied by any of Contracting States after signature date of this Convention in amendment or instead of the existing taxes. Competent authorities of Contracting States will notify each other on any essential changes in their tax legislations.
1. For the purposes of this Convention if other does not follow from context:
(a) the term "Uzbekistan" means the Republic of Uzbekistan and when using in geographical sense means the territory of the Republic of Uzbekistan, including territorial waters and airspace within which the Republic of Uzbekistan can perform the sovereign rights and jurisdiction, including the rights to use the subsoil and natural resources by the legislation of the Republic of Uzbekistan and according to international law;
(b) the term "United Kingdom" means Great Britain and Northern Ireland, and when using in geographical sense means the territory and the territorial sea and area outside the territorial sea over which Great Britain and Northern Ireland performs the sovereign rights and jurisdiction according to the national and international legal system;
c) the term "national person" means:
(I) in relation to Uzbekistan - any citizen of the Republic of Uzbekistan and any legal entity, partnership, association or other education which received the status according to the current legislation of Uzbekistan;
(II) in relation to the United Kingdom - any citizen of Britain or any face of Britain which does not have nationality of any other country of the British Empire or the territory granting it the right to residence in the United Kingdom; or any legal entity, partnership, association or other education which received the status according to the current legislation of the United Kingdom;
d) the terms "Contracting State" and "other Contracting State" mean Uzbekistan or the United Kingdom on context.
e) the term "person" means physical person, the company or any education of persons, but in relation to Item 2 of this Article does not include partnership or joint business;
f) the term "company" means any corporate consolidation or any organization which is considered as corporate education for the purpose of the taxation;
g) the term "company of the Contracting State" and "company of other Contracting State" means respectively the company operating under control of resident of the Contracting State and the company operating under control of resident of other Contracting State;
h) the term "international delivery" means any transportation sea, the aircraft, railway or the automotive vehicle used by the company of one Contracting State, except for, when sea, the aircraft, railway or the automotive vehicle are used only between the Items located in the territory of other Contracting State.
(i) "competent authority" means the term:
(i) in relation to Uzbekistan - the chairman of the State Tax Committee or its authorized representative;
(ii) in relation to the United Kingdom - brokers of royal Service of the income and customs payments or their authorized representative;
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