xmlns:atom="http://www.w3.org/2005/Atom"
WHEREAS:
1.Article 17 of Directive 2003/48/EEC (“the Directive”) of the Council...
4.The “withholding tax” referred to in the Directive will be...
7.The Isle of Man has legislation relating to undertakings for...
Article 1 Retention of Tax by Paying Agents
Interest payments as defined in Article 8 of this Agreement...
Article 2 Reporting of Information by Paying Agents
(1) Where interest payments, as defined in Article 8 of...
Article 3 Exceptions to the Retention Tax Procedure
(1) The Isle of Man when levying a retention tax...
Article 4 Basis of assessment for retention tax
(1) A paying agent established in the Isle of Man...
Article 5 Definition of beneficial owner
(1) For the purposes of this Agreement, “beneficial owner” shall...
Article 6 Identity and residence of beneficial owners
(1) Each Party shall, within its territory, adopt and ensure...
Article 7 Definition of paying agent
(1) For the purposes of this Agreement, “paying agent” means...
Article 8 Definition of interest payment
(1) For the purposes of this Agreement “interest payment” shall...
Article 9 Retention Tax Revenue sharing
(1) The Isle of Man shall retain 25% of the...
Article 10 Elimination of double taxation
(1) A contracting party in which the beneficial owner is...
Article 11 Transitional provisions for negotiable debt securities
(1) During the transitional period referred to in Article 14...
Article 12 Mutual agreement procedure
Where difficulties or doubts arise between the parties regarding the...
(1) All information provided and received by the competent authority...
Article 14 Transitional Period
At the end of the transitional period as defined in...
Subject to the provisions of Article 17 of this Agreement,...
(1) This Agreement shall remain in force until terminated by...
Article 17 Application and suspension of application
(1) The application of this Agreement shall be conditional on...
Annex: List of related entities referred to in Article 11
For the purposes of Article 11 of this Agreement, the...
The provisions of Article 11 are without prejudice to any...
Note from Her Majesty’s Government
Dear Mr Corkhill,
I have the honour to refer to the texts of...
In view of the above mentioned agreed texts, and respecting...
I have the honour to propose that, if the above...
Please accept, Sir, the assurance of our highest consideration,
Note from the Government of the Isle of Man
Dear Lord Falconer,
I have the honour to acknowledge receipt of your letter...
I am able to confirm that the Isle of Man...
I shall notify you directly once our constitutional formalities are...
Yours sincerely