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FIRST EXCHANGE OF NOTES

SECOND EXCHANGE OF NOTES

CONVENTION BETWEEN HIS MAJESTY IN RESPECT OF THE UNITED KINGDOM AND THE PRESIDENT OF THE FRENCH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

ARTICLE I - Taxes Covered

ARTICLE II - General Definitions

ARTICLE III - Business Profits

ARTICLE IV

ARTICLE V - Associated Enterprises

ARTICLE VI

ARTICLE VII

ARTICLE VIII - Shipping, Inland Waterways Transport and Air Transport

ARTICLE IX - Dividends, Interest

ARTICLE X - Royalties

ARTICLE XI - Capital Gains

ARTICLE XII - Income from Immovable Property

ARTICLE XIII - Government Service

ARTICLE XIV - Independent Personal Services

ARTICLE XV - Pensions

ARTICLE XVI

ARTICLE XVII - Teachers and Researchers

ARTICLE XVIII - Students

ARTICLE XIX

ARTICLE XX - Elimination of Double Taxation

ARTICLE XXI - Exchange of Information

ARTICLE XXII - Non-Discrimination

ARTICLE XXIII - Territorial Extension

ARTICLE XXIV

ARTICLE XXV - Entry into Force

ARTICLE XXVI - Termination