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PART 2 PROTOCOL
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Revised Laws of Saint Lucia (2023)

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PART 2
PROTOCOL

  1.  

    The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America,

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    Desiring to conclude a supplementary Protocol modifying in certain respects the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income which was signed at Washington on April 16th, 1945,

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    Have agreed as follows :

ARTICLE 1

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    Paragraph (3) of Article XI of the Convention of April 16th, 1945, for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income shall be deemed to be deleted and of no effect.

ARTICLE II

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    This Protocol, which shall be regarded as an integral part of the said Convention, shall be ratified and the instruments of ratification thereof shall be exchanged at Washington.

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    IN WITNESS WHEREOF the undersigned Plenipotentiaries, being authorized thereto by their respective Governments, have signed this Protocol and have affixed thereto their seals.

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    DONE at Washington, in duplicate, this sixth day of June, 1946.

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    FOR THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND:

    john balfour,
    His Majesty's
    Envoy Extraordinary and Minister Plenipotentiary in Washington.
  1.  

       FOR THE GOVERNMENT OF THE UNITED STATES OF AMERICA:

    james f. byrnes,
    Secretary of State of the United States of America,
  1.  

    SUPPLEMENTARY PROTOCOL AMENDING THE CONVENTION FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME, SIGNED AT WASHINGTON ON THE 16TH APRIL, 1945, AS MODIFIED BY THE SUPPLEMENTARY PROTOCOL, SIGNED AT WASHINGTON ON THE 6TH JUNE, 1946.

  1.  

    The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America,

  1.  

    Desiring to conclude a further supplementary Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Washington on the 16th April, 1945, as modified by the Supplementary Protocol, signed at Washington on the 6th June, 1946,

  1.  

    Have agreed as follows :

ARTICLE 1

  1.  

    Paragraph (1) of Article XXII of the Convention of the 16th April, 1945, for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income is hereby amended to read as follows :

  1.  

    “(1)   Either of the Contracting Parties may, at any time while the present Convention continues in force, by a written notification given to the other Contracting Party through the diplomatic channel, declare its desire that the operation of the present Convention, either in whole or in part or with such modifications as may be found necessary for special application in a particular case, shall extend to all or any of its territories for whose international relations it is responsible, which impose taxes substantially similar in character to those which are the subject of the present Convention. When the other Contracting Party has, by a written communication through the diplomatic channel, signified to the first Contracting Party that such notification is accepted in respect of such territory or territories, the present Convention, in whole or in part or with such modifications as may be found necessary for special application in a particular case, as specified in the notification, shall apply to the territory or territories named in the notification on and after the date or dates specified therein. None of the provisions of the present Convention shall apply to any such territory in the absence of such acceptance in respect of that territory.”

ARTICLE II

  1.  

    This supplementary Protocol, which shall be regarded as an integral part of the said Convention, shall be ratified and the instruments of ratification thereof shall be exchanged in London.

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    IN WITNESS WHEREOF the undersigned, being authorized thereto by their respective Governments, have signed this supplementary Protocol and have affixed thereto their seals.

  1.  

    DONE in duplicate at Washington this twenty-fifth day of May, 1954.

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    FOR THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND :

    Roger Makins,
    Her Majesty's
    Ambassador Extraordinary and Plenipotentiary at Washington.
  1.  

       FOR THE GOVERNMENT OF THE UNITED STATES OF AMERICA :

    John Foster Dulles,
    Secretary of State of the United States of America.
  1.  

       SUPPLEMENTARY PROTOCOL BETWEEN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE UNITED STATES OF AMERICA AMENDING THE CONVENTION FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME, SIGNED AT WASHINGTON ON THE 16TH APRIL 1945, AS MODIFIED BY THE SUPPLEMENTARY PROTOCOL SIGNED AT WASHINGTON ON THE 6TH JUNE 1946 AND BY THE SUPPLEMENTARY PROTOCOL SIGNED AT WASHINGTON ON THE 25TH MAY 1954.

  1.  

    The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the United States of America,

  1.  

    Desiring to conclude a further supplementary Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Washington on the 16th April 1945, as modified by the supplementary Protocol signed at Washington on the 6th June 1946 and by the supplementary Protocol signed at Washington on the 25th May 1954,

  1.  

    Have agreed as follows :

ARTICLE 1

  1.  

    Paragraphs (1) and (2) of Article VIII of the Convention of the 16th April 1945 for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income are hereby amended to read as follows :

  1.  

    “(1)   Royalties and other amounts paid as consideration for the use of, or for the privilege of using, copyrights, patents, designs, secret processes and formulae, trade marks and other like property, and derived from sources within the United States by a resident of the United Kingdom who is subject to United Kingdom tax on such royalties or other amounts shall be exempt from United States tax (a) if such resident is not engaged in trade or business in the United States through a permanent establishment situated therein or (b) if such resident is so engaged, the royalties or other amounts are not directly associated with the business carried on through that permanent establishment.

  1.  

    (2)   Royalties and other amounts paid as consideration for the use of, or for the privilege of using, copyrights, patents, designs, secret processes and formulae, trade marks, and other like property, and derived from sources within the United Kingdom by a resident of the United States who is subject to United States tax on such royalties or other amounts shall be exempt from United Kingdom tax (a) if such resident is not engaged in trade or business in the United Kingdom through a permanent establishment situated therein or (b) if such resident is so engaged, the royalties or other amounts are not directly associated with the business carried on through that permanent establishment.”

ARTICLE II

  1.  

    Paragraph (1) of Article XIII of the said Convention is hereby amended to read as follows :

  1.  

    “(1)   Subject to Sections 901 to 905 of the United States Internal Revenue Code as in effect on the 1st day of January 1956, United Kingdom tax shall be allowed as a credit against United States tax. For this purpose

    1.  

      (a)     the recipient of a dividend paid by a corporation which is a resident of the United Kingdom shall be deemed to have paid the United Kingdom tax appropriate to such dividend, and

    1.  

      (b)     the recipient of any royalty or other amount coming within the scope of Article VIII of the present Convention shall be deemed to have paid any United Kingdom tax legally deducted from the royalty or other amount by the person by or through whom any payment thereof is made,

  1.  

    if the recipient of the dividend or royalty or other amount, as the case may be, elects to include in his gross income for the purposes of United States tax the amount of such United Kingdom income tax.”

ARTICLE III

  1.  

    (1)   This supplementary Protocol shall be ratified and the instruments of ratification shall be exchanged at London as soon as possible.

  1.  

    (2)   This supplementary Protocol shall enter into force upon the exchange of instruments of ratification and shall thereupon have effect—

    1.  

      (a)     In the United Kingdom:

      1.  

        (1)     as respects income tax and surtax for any year of assessment beginning on or after the 6th April 1956;

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        (ii)     as respects profits tax for any chargeable accounting period beginning on or after the 1st April 1956, and for the unexpired portion of any chargeable accounting period current at that date.

    1.  

      (b)     In the United States:

  1.  

    As respects taxable years beginning on or after the 1st January 1956.

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    IN WITNESS WHEREOF the undersigned, being authorised thereto by their respective Governments, have signed this supplementary Protocol and have affixed thereto their seals.

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    Done in duplicate at Washington this nineteenth day of August, 1957.

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    For the Government of the United Kingdom of Great Britain and Northern Ireland:

    (L.S.)Harold Caccia.
  1.  

       For the Government of the United States of America:

    (L.S.)John Foster Dulles.

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