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(This note is not part of the Order)
The Protocol scheduled to this Order makes certain alterations to the Agreement with Venezuela which was signed on 8th March 1978 and which entered into force on 8th June 1987.
The principal amendment is the re-defining of “the business of shipping and air transport” to exclude the transportation of hydrocarbons (Article III). This means that, so far as concerns the carriage of hydrocarbons, the profits, income and capital gains derived from one country from the business of shipping by an undertaking of the other country may be taxed in both countries. The profits, income and capital gains derived from the business of shipping other cargoes by an undertaking of one country remain exempt from tax in the other country.
The Protocol will take effect in both countries from 1st January 1988.
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