EXPLANATORY NOTE
(This note is not part of the Order)
The Schedule to the Order contains a Convention and Protocol (“the Arrangements”) between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Austria dealing with the avoidance of double taxation and the prevention of tax evasion and avoidance. The 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.
The Arrangements will take effect as follows:
(a) in Austria, in respect of Austrian taxes for any fiscal year beginning on or after 1st January next following the date of entry into force of the Arrangements,
(b) in the United Kingdom:
(i) 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 of the Arrangements; 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 of the Arrangements.
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 the Order as it gives effect to a double taxation agreement. Double taxation agreements impose no obligations on taxpayers, rather they seek to eliminate double taxation and fiscal evasion.