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HMRC internal manual

Double Taxation Relief Manual

Italy: Government service

Although Article 19 of the new agreement is worded in a standard manner (see INTM163170 onwards), it has been agreed to extend the scope of the Article to cover remuneration and pensions paid to the employees of the following

  1. with respect to the United Kingdom
* the Commonwealth War Graves Commission
* the British Council
* the British School of Rome
* the British Institute of Florence.
  1. with respect to Italy
* the Italian Railway Administration (FS)
* the Administration of Postal and Telecommunication Services (PPTT)
* the Italian National Tourist Office (ENIT)
* the National Institute for Foreign Trade (ICE)
* the Bank of Italy (Banca d'Italia)
* the Italian Institute of Culture in London and Edinburgh.

Any claim to extend further the scope of the Article should be referred to HMRC, Customs & International, Tax Treaty Team .