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1Article 1 · Personal scope2Article 2 · Taxes covered3Article 3 · General definitions4Article 4 · Residence5Article 5 · Permanent establishment6Article 6 · Income from immovable property7Article 7 · Business profits8Article 8 · Shipping, inland waterways transport and air transport9Article 9 · Associated enterprises10Article 10 · Dividends11Article 11 · Interest12Article 12 · Royalties13Article 13 · Capital gains14Article 14 · Independent personal services15Article 15 · Dependent personal services16Article 16 · Directors’ fees17Article 17 · Artistes and athletes18Article 18 · Pensions19Article 19 · Government service20Article 20 · Students21Article 21 · Other income22Article 22 · Elimination of double taxation23Article 23 · Non-discrimination24Article 24 · Mutual agreement procedure25Article 25 · Exchange of information26Article 26 · Diplomatic agents and consular officers27Article 27 · Miscellaneous rules27aArticle 27A · Entitlement to benefits28Article 28 · Entry into force29Article 29 · TerminationPreamble · Title, publisher explanation and complete preambleSignature · Signature and authentic-language clauseAdditional Protocol · Integral Additional Protocol dated 7 September 2009

30 articles · English

Source & edition
Country pairs / Switzerland / United Kingdom

Switzerland / United Kingdom · Switzerland–United Kingdom 1977 Convention: official amended publication

Article 3 · General definitions

English · amended source publication

Unreviewed · applicability unverifiedProtocol entry-date conflict: 16 / 19 July 2019
Original & source
§
(1) In this Convention, unless the context otherwise requires:
§
(a) the term “United Kingdom” means Great Britain and Northern Ireland, including any area outside the territorial sea of the United Kingdom which in accordance with international law has been or may hereafter be designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which the rights of the United Kingdom with respect to the sea-bed and sub-soil and their natural resources may be exercised;
§
(b) the term “Switzerland” means the Swiss Confederation;
§
(c) the terms “a Contracting State” and “the other Contracting State” mean the United Kingdom or Switzerland, as the context requires;
§
(d) the term “tax” means United Kingdom tax or Swiss tax, as the context requires;
§
(e) the term “person” includes any individual, company, unincorporated body of persons, and any other entity with or without juridical personality;
§
(f) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes;
§
(g) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
§
(h) the term “national” means:
§
(i) in relation to the United Kingdom, any citizen of the United Kingdom and Colonies, or any British subject not possessing that citizenship or the citizenship of any other Commonwealth country or territory, provided in either case he has the right of abode in the United Kingdom, and any legal person, partnership, association or other entity deriving its status as such from the law in force in the United Kingdom;
§
(ii) in relation to Switzerland, any Swiss citizen and any legal person, partnership, association or other entity deriving its status as such from the law in force in Switzerland;
§
(i) the term “international traffic” means any transport by a ship or aircraft operated by an enterprise which has its place of effective management in a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
§
(j) the term “competent authority” means in the United Kingdom, the Commissioners of Inland Revenue or their authorised representative and in Switzerland, the Director of the Federal Tax Administration or his authorised representative;
§
(k) the term “political subdivision”, in relation to the United Kingdom, includes Northern Ireland.
§
(2) As regards the application of the Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes which are the subject of the Convention.
Citation to select or copy

Switzerland / United Kingdom; HMRC, 1977 UK-Switzerland Double Taxation Convention as amended by the 2017 protocol; edition 1977 Convention amended by 1981, 1993, 2007, 2009 and 2017 Protocols; HMRC updated 29 September 2021; article 3; English; unreviewed source text, current applicability unverified; /editions/ch-gb-1977-hmrc-amended-2017-html-v1/en/articles/article-3/

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Source & edition

HMRC, 1977 UK-Switzerland Double Taxation Convention as amended by the 2017 protocol

  • Official online text · retained capture Official source website ↗

    SHA-256 47363996866f352e121f3af31a77eac604d566eab9b948ff9a62bb11114ce474

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Edition
1977 Convention amended by 1981, 1993, 2007, 2009 and 2017 Protocols; HMRC updated 29 September 2021
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Signature
1977-12-08

Languages recorded in source metadata: English. This is not a promise of available text or a translation.

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Complete preamble, closing and all supplied integral protocol/notes are retained separately and searchable within this source.

Publisher date discrepancy retained: amended-publication introduction says 2017 Protocol entered into force 16 July 2019; HMRC country index says 19 July 2019. No protocol entry-into-force date asserted in structured dates.

This is the 1977 Convention, not the older 1966 publication.

Source authority, text completeness and currentness still require human review.

2017 Protocol entry-into-force date differs between HMRC publication and index. do not assert a structured protocol entry-into-force date; wording preserved

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