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EXPLANATORY NOTE

(This note is not part of the Order)

The Schedule to this Order contains a Convention and a Protocol (“the Arrangements”) between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Iceland dealing with the avoidance of double taxation and the prevention of fiscal evasion. This Order brings the Arrangements into effect.

The Arrangements aim to eliminate the double taxation of income and gains arising in one country and paid to residents of the other country. This is done by allocating the taxing rights that each country has under its domestic law over the same income and gains, and/or by providing relief from double taxation. There are also specific measures which combat discriminatory tax treatment and provide for assistance in international tax enforcement.

Article 1 provides for citation.

Article 2 makes a declaration as to the effect and content of the Arrangements.

The Arrangements will enter into force on the date of the later of the notifications by each country of the completion of its legislative procedures. They will take effect as follows:

(a)in respect of taxes withheld at source, to income derived on or after 1st January next following the date of entry into force;

(b)in Iceland, in respect of other taxes on income, to taxes chargeable for any tax year beginning on or after 1st January next following the date of entry into force; and

(c)in the United Kingdom:

(i)subject to paragraph (a) above, in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6th April next following the date of entry into force; and

(ii)in respect of corporation tax, for any financial year beginning on or after 1st April next following the date of entry into force.

Until such time as the Arrangements enter into force, the Convention set out in the Schedule to the Double Taxation Relief (Taxes on Income) (Iceland) Order 1991 (S.I. 1991/2879), continues to have effect.

The date of entry into force will, in due course, be published in the London, Edinburgh and Belfast Gazettes.

A Tax Information and Impact Note has not been produced for this Order as it gives effect to a previously announced policy to enact a double taxation agreement.