United Kingdom / Italy · United Kingdom–Italy 1988 Convention: official base Convention

Official base Convention; HMRC published 6 August 2006

Article 9 · associated enterprises

English · original source edition

Unreviewed · applicability unverified1988 base text and notes

- Where

- (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or

- (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,

- and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.

Citation to select or copy

United Kingdom / Italy; HMRC, 1988 UK-Italy Double Taxation Convention — in force; edition Official base Convention; HMRC published 6 August 2006; article 9; English; source role publisher-source-edition; Publisher source edition; not current-law certification; unreviewed source text, current applicability unverified; /editions/gb-it-1988-hmrc-base-html-reserve-v1/en/articles/article-9/

Disclaimers

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

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

Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.

Noindex is not access control. This is a research preview, not a statement of authoritative or current law.

Source & edition

HMRC, 1988 UK-Italy Double Taxation Convention — in force

Official online text · retained capture Official source website ↗
SHA-256 4c73ff5ca869765ab1ff88dc551b0d2cc44c420a58b105c08c376e712b322e37
Digest scope: retained online-source capture; no PDF binary verification

Publisher role and language

source publication only; current applicability not certified

MLI and current applicability not independently verified.

Actual supplied body languages: English. A language named by an instrument is not a supplied translation.

Edition: Official base Convention; HMRC published 6 August 2006
Text available here: English
Review: Unreviewed; qualified human review pending
Current applicability: Not verified

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

Edition notes and known limitations

Official HTML text capture, not Original PDF; human wording and current-law certification not claimed.

Block IDs are navigation aids, never invented legal paragraph numbers. Native extraction can flatten ordered-list styling; only printed source labels are retained.

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

No assistant consolidation or current-law certification; later changes must be researched separately.

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

Retained metadata & integrity record

All articles in this edition · Other editions for this pair