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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Tuvalu and Kiribati: double taxation agreement, Article 9 Income from personal (including professional) services

(1) An individual who is a resident of the United Kingdom-shall be exempt from Colonialtax on profits or remuneration in respect of personal (including professional) servicesperformed within the Colony in any year of assessment if-

(a) he is present within the Colony for a period or periods not exceeding in the aggregate 183 days during that year, and
(b) the services are performed for or on behalf of a person resident in the United Kingdom, and
(c) the profits or remuneration are subject to United Kingdom tax.

(2) An individual who is a resident of the Colony shall be exempt from United Kingdomtax on profits or remuneration in respect of personal (including professional) servicesperformed within the United Kingdom in any year of assessment if-

(a) he is present within the United Kingdom for a period or periods not exceeding in the aggregate 183 days during that year, and
(b) the services are performed for or on behalf of a person resident in the Colony, and
(c) the profits or remuneration are subject to Colonial tax.

(3) The provisions of this paragraph shall not apply to the profits or remuneration ofpublic entertainers such as stage, motion picture or radio artists, musicians andathletes.