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Georgetown

31st August 1992

Excellency

I am in receipt of your Note dated August 31st, 1992 which states as follows:

I have the honour to refer to the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Co-operative Republic of Guyana for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains which has been signed today and to propose on behalf of the Government of the United Kingdom that, in applying paragraph (4) of Article 25 (Non-Discrimination) of that Convention, the expression “Other similar enterprises of the first-mentioned State” should be interpreted as referring to enterprises of the United Kingdom or Guyana as the case may be the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more persons who are not residents of the United Kingdom or Guyana.

The foregoing proposal being acceptable to the Government of Guyana, I have the honour to confirm that Your Excellency’s Note and this Reply should be regarded as constituting an agreement between the two Governments in this matter.

I take this opportunity to renew to Your Excellency the assurances of my highest consideration.

Winston Murray

His Excellency the Deputy

Prime Minister, Trade, Tourism

and Industry performing the

duties of the Minister of Finance

of the Co-operative Republic

of Guyana

  1. ICONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF THE CO-OPERATIVE REPUBLIC OF GUYANA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS
  2. Article 1Personal scope
  3. Article 2Taxes covered
  4. Article 3General definitions
  5. Article 4Resident
  6. Article 5Permanent establishment
  7. Article 6Limitation of relief
  8. Article 7Income from immovable property
  9. Article 8Business profits
  10. Article 9Shipping and air transport
  11. Article 10Associated enterprises
  12. Article 11Dividends
  13. Article 12Interest
  14. Article 13Royalties
  15. Article 14Technical fees
  16. Article 15Capital Gains
  17. Article 16Independent personal services
  18. Article 17Dependent personal services
  19. Article 18Directors' fees
  20. Article 19Artistes and athletes
  21. Article 20Pensions
  22. Article 21Government service
  23. Article 22Students and trainees
  24. Article 23Other income
  25. Article 24Elimination of double taxation
  26. Article 25Non-discrimination
  27. Article 26Mutual agreement procedure
  28. Article 27Exchange of information
  29. Article 28Members of diplomatic or permanent missions and consular posts
  30. Article 29Entry into force
  31. Article 30Termination
  32. IIEXCHANGE OF NOTES