Schedule CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF THE KINGDOM OF LESOTHO FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS
The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Kingdom of Lesotho;
Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains;
Have agreed as follows:
- Article 1Personal scope
- Article 2Taxes covered
- Article 2General definitions
- Article 4Residence
- Article 5Permanent establishment
- Article 6Income from immovable property
- Article 7Business profits
- Article 8Shipping and air transport
- Article 9Associated enterprises
- Article 10Dividends
- Article 11Interest
- Article 12Royalties
- Article 13Management and technical fees
- Article 14Capital Gains
- Article 15Independent personal services
- Article 16Dependent personal services
- Article 17Directors' fees
- Article 18Artistes and sportsmen
- Article 19Pensions and annuities
- Article 20Government service
- Article 21Students
- Article 22Other income
- Article 23Elimination of double taxation
- Article 24Limitation of relief
- Article 25Non-discrimination
- Article 26Mutual agreement procedure
- Article 27Exchange of information
- Article 28Members of diplomatic or permanent missions and consular posts
- Article 29Entry into force
- Article 30Termination