Explanatory Note

(This note is not part of the Order)

The Protocol scheduled to this Order makes certain alterations to the Convention set out in the Schedule to the Double Taxation Relief (Taxes on Income) (Austria) Order 1970, as amended by the Protocol set out in the Schedule to the Double Taxation Relief (Taxes on Income) (Austria) Order 1979.

The Protocol replaces Article 17 of the Convention by a new Article providing that income derived by a resident of one State from activities as an artiste or athlete may be taxed in the other State. Furthemore, if the income accrues to a person other than the artiste or athlete then the income may also be taxed in the State where the activities are exercised.

Provision is also made for the fees of non-profit making organisations performing under cultural agreements to be exempt from tax in the State in which the activities are exercised.

The Protocol will enter into force on first day of the third month after ratification and will have effect both in the UK and Austria for tax years beginning on or after 1st January 1994.