b) an enterprise shall be thought to be related to another enterprise if one is controlled immediately or not directly by the opposite, or each are controlled directly or indirectly by a 3rd person or individuals. This Convention could also be prolonged, both in its entirety or with any necessary modifications, to any territory to which this Article applies and which imposes taxes considerably related in character to those to which the Convention applies.






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Royalties arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that different State if that resident is the useful proprietor of the royalties. Interest arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that different State if that resident is the beneficial proprietor of the curiosity. In such case, the provisions of Article 6 or 14 of this Convention, because the case could also be, shall apply.






Items of earnings beneficially owned by a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State. Subject to the provisions of paragraphs 1 and a pair of of Article 19, any pension and different related remuneration paid in consideration of previous employment to a resident of a Contracting State and any annuity paid to such a resident shall be taxable solely in that State. Such income derived from the United Kingdom by a resident of France can also be taxed in France. Notwithstanding the previous provisions of this Article, remuneration in respect of an employment exercised aboard a ship or plane in international traffic could also be taxed in the Contracting State in which the place of effective administration of the enterpriseis located. Subject to the provisions of Articles 16, 18, 19 and 20, martinique 1ere programme tv salaries, wages and other comparable remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable solely in that State until the employment is exercised within the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that different State. Income derived by a resident of a Contracting State in respect of unbiased skilled actions shall be taxable solely in that State except he has a hard and fast base frequently obtainable to him within the other Contracting State for the aim of performing his activities.






If he has such a fixed base, the revenue may be taxed in the different Contracting State but solely so much of it as is attributable to that fixed base. Gains derived by a resident of a Contracting State from the alienation of immovable property, as outlined in paragraph 2 of Article 5, which is located within the different State could also be taxed in that different State. For the needs of this provision the second sentence of paragraph 2 of Article 5 shall not apply.






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The only way to leave a evaluation is to first make a reserving.‒ Coniopteryx borealis‚ new species for the Algerian fauna‚ and up-to-date verify-record of Coniopterygidae from Algeria .It is characterized by a great dimension surpassing that of the other representatives of the subgenus Pinocapsus‚ a greyish colour and the stoutness and nice improvement of the male genitalia.In the female‚ the apical parts of the laterotergites eight are asymmetric and unusual in being tightly welded with the protuberances of the gonapophyses eight.Coniopteryx borealis Tjeder‚ 1930‚ was collected throughout a bioecological study of citrus entomofauna.













Any such extension shall take effect from such date and subject to such modifications and circumstances, together with conditions as to termination, as may be specified and agreed between the Contracting States in Notes to be exchanged for this purpose. In France where the income or earnings of an enterprise are adjusted pursuant to Article 8, taxes shall be imposed on such revenue or income, or refund of taxes shall be allowed in accordance with the settlement reached by the competent authorities respecting such changes. In such case aid from tax shall be given in the identical means as if the pension scheme was recognised as such by that State and payments to the pension scheme by the enterprise paying his remuneration shall not be deemed to be taxable income of the person. In determining for the purpose of United Kingdom tax whether a company is an in depth firm the term "recognised inventory change" shall embrace any stock change set up in France in accordance with the French laws. Subject to paragraph three of this Article, individuals who're residents of the United Kingdom shall be entitled to the identical private allowances, reliefs and reductions for the purposes of French tax as French nationals resident within the United Kingdom. Subject to paragraph 3 of this Article, people who're residents of France shall be entitled to the same personal allowances, reliefs and reductions for the needs of United Kingdom taxation as British topics not resident within the United Kingdom.
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