EXPLANATORY NOTE

(This note is not part of the Order)

The Schedule to this Order contains an agreement (“the Agreement”) dealing with the exchange of information for tax purposes between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of San Marino. This Order brings the Agreement into effect.

Article 1 provides for citation.

Article 2 makes a declaration as to the effect and content of the Agreement.

The Agreement provides for the exchange of information relevant to the administration or enforcement or recovery of the taxes covered by the Agreement by the revenue authorities of the two countries. Information will be exchanged in accordance with the provisions of the Agreement.

The Agreement will enter into force on the date of the later of the notifications by each country of the completion of its legislative procedures. It will take effect as follows:

a

in respect of requests relating to criminal tax matters, on the date of entry into force; and

b

in respect of all other requests, for taxable periods beginning on or after the 1st January of the year next following the date of entry into force, or where there is no taxable period, for all charges to tax arising on or after 1st January of the year next following that date.

The date of entry into force will, in due course, be published in the London, Edinburgh and Belfast Gazettes.

In line with government commitments, a Tax Information and Impact Note has not been prepared for this Order as it gives effect to a previously announced policy to enact a tax information exchange agreement.