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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Swaziland: double taxation agreement, Article 27: Entry into force

(1) This Agreement shall come into force on the date when the last of all such things shall have been done in the United Kingdom and Swaziland as are necessary to give the Agreement the force of law in the United Kingdom and Swaziland respectively, and shall thereupon have effect-

(a) in the United Kingdom–

(i) as respects income tax (including surtax) and capital gains tax, for any year of assessment beginning on or after 6 April, 1968, and
(ii) as respects corporation tax, for any financial year beginning on or after 1 April, 1968;

(b) in Swaziland–

(i) as respects normal tax, for any year of assessment ending after 30 June, 1968;
(ii) as respects non-resident shareholders’ tax on dividends declared after 30 June, 1968, and
(iii) as respects non-residents’ tax on interest, on interest payable after 30 June. 1968.
(2) Subject to paragraphs (3) and (4) of this Article the Arrangement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income which was made in 1949(a) between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Swaziland shall cease to have effect as respects taxes to which this Agreement in accordance with paragraph (1) of this Article applies.

(3) Subject to paragraph (4) of this Article, where any provision of the Arrangement referred to in paragraph (2) of this Article would have afforded any greater relief from tax any such provision as aforesaid shall continue to have effect for any year of assessment or financial year beginning before the entry into force of this Agreement.

(4) Where any greater relief from Swaziland tax would have been afforded by sub- paragraph (1) of paragraph 6 of the Arrangement referred to in paragraph (2) of this Article than is afforded by Article 11 of this Agreement, the aforesaid sub-paragraph (1) of paragraph 6 shall continue to have effect in respect of dividends declared on or before the day following the date of signature of this Agreement.

(5) The Arrangement referred to in paragraph (2) of this Article shall terminate on the last date on which it has effect in accordance with the foregoing provisions of this Article.