Explanatory Note

(This note is not part of the Order)

The Arrangement scheduled to this Order amends the Arrangement between the United Kingdom and the Isle of Man which is scheduled to the Double Taxation Relief (Taxes on Income) (Isle of Man) Order 1955 as amended by the Arrangement set out in the Schedule to the Double Taxation Relief (Taxes on Income) (Isle of Man) Order 1991.

The effect of the amendment is to make relief or exemption from United Kingdom tax under the 1955 Arrangement dependent on a person who is entitled to the benefit of certain special provisions of Isle of Man law being assessed under those provisions on the whole of his income at the standard rate of tax in force in the Isle of Man at the relevant time.

The Arrangement will have effect in respect of income and profits arising on and after the date on which the Arrangement enters into force. The date of entry into force will in due course be published in theLondon, EdinburghandBelfast Gazettes.