Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United Mexican States for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains

• Coming into Force: 15 December 1994
• Citation: UNTS v. 1913
• Date of Conclusion: 02 June 1994
• Registration Date: 23 February 1996
• Registration Number: 32642
• Subject Terms: Finance,Taxation
• Type of Document: Bilateral
• Participants: México,United Kingdom of Great Britain and Northern Ireland
• Party Submitting the Application for Registration: United Kingdom of Great Britain and Northern Ireland

No.

32642

UNITED KINGDOM

OF

GREAT

BRITAIN

AND

NORTHERN

IRELAND

and

MEXICO

Convention

for

the

avoidance

of

double

taxation

and

the

pre-

vention

of

fiscal

evasion

with

respect

to

taxes

on

income

and capital

gains

(with

exchange

of

notes).

Signed

at

Mexico

City

on

2

June

1994

Authentic

texts:

English

and

Spanish.

Registered

by

the

United

Kingdom

of

Great

Britain

and

Northern

Ireland

on

23

February

1996.

ROYAUME-UNI DE

GRANDE-BRETAGNE

ET

D'IRLANDE

DU

NORD

et

MEXIQUE

Convention

tendant

i

eviter

la

double

imposition

et

ii

prove-

nir

l'6vasion

fiscale

en

matiere

d'imp6ts

sur

le

revenu

et

sur

les

gains

en

capital

(avec

change

de

notes).

Sign~e

it

Mexico

le

2

juin

1994

Textes

authentiques

:

anglais et

espagnol.

Enregistrie

par

le

Royaume-Uni

de

Grande-Bretagne

et

d'Irlande

du

Nord

le

23fivrier

1996.

Vol.

1913,

1-32642

140

United Nations

-

Treaty

Series

*

Nations

Unies

-Recueil

des

Traitks

1996

CONVENTION'

BETWEEN

THE

GOVERNMENT OF

THE

UNITED

KINGDOM

OF

GREAT BRITAIN

AND

NORTHERN

IRELAND

AND

THE

GOVERNMENT

OF

THE UNITED

MEXICAN

STATES

FOR

THE

AVOIDANCE

OF

DOUBLE

TAXATION

AND

THE

PRE-

VENTION

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

United

Mexican

States;

Desiring

to

conclude

a

new

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

1

Personal

scope

This

Convention

shall apply

to

persons

who

are

residents

of

one

or

both

of

the

Contracting

States.

ARTICLE

2

Taxes

covered

(1)

The

taxes

which are

the

subject

of

this

Convention

are:

(a)

in

the

case

of

Mexico:

the

income

tax

(el

impuesto

sobre

la

renta);

(hereinafter

referred

to

as

"Mexican

tax").

(b)

in

the

case

of

the

United

Kingdom:

(i)

the

income

tax;

(ii)

the

corporation

tax;

(iii)

the capital

gains

tax;

(hereinafter

referred

to

as

"United

Kingdom

tax").

(2)

This

Convention

shall also apply

equally

to

any

identical

or

substantially

similar

taxes

which

are imposed

by

either

Contracting

State

or

by

any

of

its

political

subdivisions

after

the date

of

signature

of

this

Convention

in

addition

to,

or

in

place

of,

the

taxes

of

the

Contracting

State

referred

to

in

paragraph

(1)

of

this

Article.

The

competent

authorities

of

the Contracting

States

shall

notify

each

other

of

any

substantial

changes which

have

been

made

in

their

respective

taxation

laws.

I

Came into

force on

15

December

1994,

the date

of

the

last

of

the

notifications

by

which

the

Contracting

Parties

informed

each

other of

the completion

of

the

required

procedures,

in

accordance

with

article

29.

Vol.

1913,

1-32642

United Nations

-

Treaty

Series

*

Nations

Unies

-Recueil

des

Traitks

ARTICLE

3

General

definitions

(1)

For

the

purposes

of

this Convention,

unless

the

context otherwise requires:

(a)

the

term

"Mexico"

means

the

United

Mexican States;

when

used

in

a

geographical

sense,

it

includes the

territory

of

the

United

Mexican

States;

as

well

as

the

integrated

parts

of

the

Federation; the

islands, including

the

reefs

and

cays

in

the

adjacent

waters;

the

islands

of

Guadalupe

and

Revillagigedo;

the

continental

shelf

and

the

seabed

and

submarine

shelves

of

the islands,

cays

and

reefs;

the

waters

of

the

territorial

seas

to

the

extent

and

limits established

by

international

law

and

the

inland

waters;

and

the

air

space

of

the

national

territory

to

the

extent

and

upon

the

conditions

established

by

international

law;

(b)

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

seabed

and

sub-soil

and

their

natural

resources may

be

exercised;

(c)

the

term

"national"

means:

(i)

in

ielation

to

Mexico:

(a)

any individual

possessing

the

nationality

of

Mexico;

and

(b)

any

legal

person,

partnership

or

association deriving

its

status

as

such

from

the

law in force in

Mexico;

(ii)

in

relation

to

the

United

Kingdom,

any

British

citizen,

or

any British

subject

not

possessing

the citizenship

of

any

other Commonwealth

country or territory,

provided

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;

(d)

the terms

"a Contracting

State"

and

"the

other

Contracting

State"

mean

Mexico

or

the

United

Kingdom,

as

the

context

requires;

(e)

the

term "person"

comprises

an

individual,

a

company

and

any

other

body

of

persons,

but

does

not

include a

partnership

which

is

not

treated

as a

body

corporate

for

tax

purposes

in

either

Contracting

State;

(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

"international

traffic"

means

any

transport

by

a

ship

or

aircraft

operated

by

an

enterprise

of

a

Contracting

State,

except

when

the

ship

or

aircraft

is

operated

solely

between

places

in

the

other

Contracting

State;

(i)

the

term "competent

authority"

means, in

the

case

of

Mexico,

the

Ministry

of

Finance

and

Public

Credit and,

in

the

case

of

the

United

Kingdom,

the

Commissioners

of

Inland

Revenue

or

their

authorised

representative.

Vol.

1913,

1-32642