3. For the purposes of this agreement, the concept of "pension" includes any payment made under a supplementary plan, pension or pension plan, retirement of the armed forces, pensions and benefits of veterans, as well as any payment under a sickness, accident or disability scheme, as well as any payments made in a contracting state under social security legislation. , but not paid as part of a pension plan to pay all future rights under such a plan or payment under an average income pension contract. 4. To the extent that it was customary in a contracting state to determine the profits attributable to a stable establishment on the basis of a distribution of the company`s total profits among its various parties, nothing in paragraph 2 prevents that State party from determining taxable profits by a customary distribution, if any; However, the allocation method used must be followed in such a way that the result is consistent with the principles set out in this article. 1. Nationals of a contracting state must not be subject, in the other contracting state, to a tax or related obligation that is other or more burdensome than the imposition and related requirements to which the nationals of that other state are or may be subject in the same circumstances. Well, Her Majesty, in exercising the powers conferred upon him by Section 497 of the Income and Corporation Taxes Act 1970, and all the other powers that allow him to do so on this behalf, he is pleased to command through and with the Council of your Privy Council, and it is ordered by this The foreign tax credit is due on the basis of the dual contract between the two countries. If both countries impose the same income, the country in which the person is domiciled could claim a tax credit for the tax paid in the country that has primary tax duties.

2. This article does not apply to the remuneration of services provided in the context of an activity carried out by one of the contracting states or by a political sub-direction or a territorial authority. 3. For the purposes of paragraphs 1 and 2 of this article, the income, profits and capital gains of a Contractant State established in a contracting state that are taxed in the other Contractant State under this Convention are considered to be from sources in that other contracting state. 8. Notwithstanding the provisions of the national legislation of the contracting states which provide for delays for applications for exemption, an application for exemption in accordance with the provisions of this convention and any resulting tax refunds come into force if the application is submitted to the competent authority within one year from the end of the calendar year in which the present agreement enters into force. It is much more common to seek the services of a qualified and experienced accountant to seek tax relief through double taxation agreements. Fees vary depending on the complexity of an individual`s personal life, in almost all cases, the tax savings far exceed all the costs of using an accountant - and they can be sure to pay the correct amount of tax with total confidence. When a person is a tax resident in the United Kingdom and also has a tax seat in another jurisdiction, i.e.

a "dual resident," and if the other jurisdiction has a tax agreement with the United Kingdom, the treaty distributes a person`s income tax and profits between the two countries. This scheme is typical of scenarios where an expatriate is employed with a local contract in the UK, but his family has stayed at home somewhere in Europe and spends three to four days in the UK and the rest of the time in the family home outside the UK.