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32 articles · English

Source & edition
Country pairs / France / United Kingdom

France / United Kingdom · United Kingdom–France 2008 Convention and integral Protocol

Article 19 · government service

English · source publication

Unreviewed · applicability unverifiedMLI modifications not incorporated
Original & source
§
- 1. Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a local authority thereof, or by a statutory body of either, to an individual in respect of services rendered to that State, authority or statutory body shall be taxable only in that State. However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident and a national of that State without being also a national of the first-mentioned State.
§
- 2. Pensions and other similar remuneration paid by, or out of funds created by, a Contracting State or a local authority thereof, or, in the case of France, a statutory body, to an individual in respect of services rendered to that State, authority or statutory body shall be taxable only in that State. However, such pension shall be taxable only in the other Contracting State if the individual is a resident and a national of that State without being also a national of the first-mentioned State.
§
- 3. The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages and other similar remuneration and to pensions in respect of services rendered in connection with a business carried on by a Contracting State or a local authority thereof or by a statutory body of either.
§
- 4. Notwithstanding any other provision of this Convention:
§
- (a) the pensions referred to in paragraph (4) of Article 81 of the French tax code (code général des impôts) shall be exempt from United Kingdom tax, regardless of the nationality of the pensioner, so long as they are exempt from French tax;
§
- (b) the pensions referred to in section 641(1)(a) to (g) of the Income Tax (Earnings and Pensions) Act 2003 and benefits paid by reason of illness or injury following the termination of service in the armed forces or reserve forces referred to in section 641(1) (h) of the Income Tax (Earnings and Pensions) Act 2003 and injury and disablement pensions payable under any scheme made under the Personal Injuries (Emergency Provisions) Act 1939 shall be exempt from French tax, regardless of the nationality of the pensioner, so long as they are exempt from United Kingdom tax. However, paragraph 2 shall apply to such part of any income from those pensions as is not exempted from United Kingdom tax.
Citation to select or copy

France / United Kingdom; HMRC 2008 UK–France Double Taxation Convention, official online publication; edition 2008 base Convention and integral Protocol; HMRC online publication updated 20 May 2019; article 19; English; unreviewed source text, current applicability unverified; /editions/fr-gb-2008-official-html-v1/en/articles/article-19/

Disclaimers

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Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.

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Source & edition

HMRC 2008 UK–France Double Taxation Convention, official online publication

  • Official online text · retained capture Official source website ↗

    SHA-256 e79446e2fbfbbd5d2fa5e3f1bb6e35d8ccef7be8d8cba70c91ed23c4b2df1a5f

    Digest scope: retained online-source capture; no PDF binary verification

Edition
2008 base Convention and integral Protocol; HMRC online publication updated 20 May 2019
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Signature
2008-06-19
Entry into force
2009-12-18
Pdf publication
Not established

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

Edition notes and known limitations

Official online text capture, not a verified Original PDF.

Base edition: known MLI modifications are not incorporated.

Printed source wording and provision numbers are retained; machine paragraph IDs are navigation IDs, not newly assigned legal numbers.

Preamble, signatures, original footnotes and integral Protocol where present are retained as supplements and search_units.

Human wording/legal currentness review not claimed.

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

Retained metadata & integrity record

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