60 STAT.] UNITED KINGDOM-DOUBLE TAXATION- Apr. 16,1945 June 6, 1946 States, (b) subject to United States tax with respect to such royalties and rentals, and (c) not engaged in trade or business in the United Kingdom, shall be exempt from United Kingdom surtax. ARTICLE X (1) Any salary, wage, similar remuneration, or pension, paid by the Government of the United States to an individual (other than a British subject who is not also a citizen of the United States) in respect of services rendered to the United States in the discharge of governmen- tal functions, shall be exempt from United Kingdom tax. (2) Any salary, wage, similar remuneration, or pension, paid by the Government of the United Kingdom to an individual (other than a citizen of the United States who is not also a British subject) in respect of services rendered to the United Kingdom in the discharge of govern- mental functions, shall be exempt from United States tax. (3) The provisions of this Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by either of the Contracting Parties for purposes of profit. ARTICLE XI (1) An individual who is a resident of the United Kingdom shall be exempt from United States tax upon compensation for personal (in- cluding professional) services performed during the taxable year within the United States if (a) he is present within the United States for a period or periods not exceeding in the aggregate 183 days during such taxable year, and (b) such services are performed for or on behalf of a person resident in the United Kingdom. (2) An individual who is a resident of the United States shall be exempt from United Kingdom tax upon profits, emoluments or other remuneration in respect of personal (including professional) services performed 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) such services are performed for or on behalf of a person resident in the United States. (3) The provisions of this Article shall not apply to the compensa- tion, profits, emoluments or other remuneration of public entertainers such as stage, motion picture or radio artists, musicians and athletes.[] ARTICLE XII (1) Any pension (other than a pension to which Article X applies), and any life annuity, derived from sources within the United States by an individual who is a resident of the United Kingdom shall be exempt from United States tax. (2) Any pension (other than a pension to which Article X applies), and any life annuity, derived from sources within the United Kingdom by an individual who is a resident of the United States shall be exempt from United Kingdom tax. I [See Protocol signed June 6, 1946, post, p. 1389.1 1383 Wages, etc., tax exemption. Compensation for personal services, tax exemption. Public entertainers. Pod, p. 1389. Pension and life annuity.
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