The United Kingdom of Great Britain and Northern Ireland and the Kingdom of the Netherlands;
Desiring to conclude a Protocol to amend the Convention between the United Kingdom of Great Britain and Northern Ireland and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Estates of Deceased Persons and Inheritances and on Gifts signed at The Hague on 11th December 1979 (hereinafter referred to as “the Convention”);
Have agreed as follows:
Paragraph (1)(a) of Article 2 of the Convention shall be deleted and replaced by the following:
“(a)in the United Kingdom, the capital transfer tax and the inheritance tax (hereinafter referred to as “United Kingdom tax”);.”
Paragraph (1)(d)(i) of Article 3 of the Convention shall be deleted and replaced by the following:
“(i)in relation to the United Kingdom, any British citizen or any British subject not possessing the citizenship of any other Commonwealth country or territory provided he had the right of abode in the United Kingdom at the time of the death or gift or any other material time;”.
In paragraph (4)(b) of Article 13 of the Convention for the words “within 3 years” there shall be substituted “within 7 years”.
In paragraph (1) of Article 19 of the Convention for the words “, as well as to the Netherlands Antilles,” there shall be substituted “, as well as to the Netherlands Antilles and Aruba,”.
(1) Each of the Contracting Parties shall notify the other of the completion of the procedure required by its law for the bringing into force of this Protocol.
(2) The Protocol shall enter into force on the date of the later of these notifications and shall thereupon have effect in respect of property by reference to which there is a charge to tax which arises after 17th March 1986.
This Protocol shall cease to be effective at such time as the Convention ceases to be effective in accordance with Article 21 of the Convention.
In witness whereof the undersigned, duly authorised thereto by their respective Governments, have signed this Protocol.
Done in duplicate at London this 7th day of September 1995 in the English and Dutch languages, both texts being equally authoritative.