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FIRST EXCHANGE OF NOTES

ANNEX PART I  - APPLICATION

PART II  - MODIFICATIONS

II

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 - [Permanent Establishment]

ARTICLE V - [Associated Enterprises]

ARTICLE VI - [Industrial and Commercial Profits]

ARTICLE VII - [Distributed Profits]

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 - [Residence]

ARTICLE XVII - [Teachers and Researchers]

ARTICLE XVIII - [Students]

ARTICLE XIX - [Personal Allowances]

ARTICLE XX - [Elimination of Double Taxation]

ARTICLE XXI - [Exchange of Information]

ARTICLE XXII - [Non-Discrimination]

ARTICLE XXIII - [Territorial Extension]

ARTICLE XXIV - [Territorial Extension]

ARTICLE XXV - [Entry into Force]

ARTICLE XXVI - [Termination]