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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Swaziland: double taxation agreement, Article 28: Termination

This Agreement shall remain in force until denounced by one of the Governments. EitherGovernment may denounce the Agreement, through diplomatic channels, by giving notice oftermination at least six months before the end of any calendar year after the year 1971.In such event, the Agreement shall cease to 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 in the calendar year next following that in which the notice is given; and
(ii) as respects corporation tax, for any financial year beginning on or after 1 April in the calendar year next following that in which the notice is given;

(b) in Swaziland-

(i) as respects taxes on income, for any year of assessment ending after 30 June in the calendar year next following that in which the notice is given;
(ii) as respects non-resident shareholders’ tax, on dividends declared after 30 June in the calendar year next following that in which the notice is given; and
(iii) as respects non-residents’ tax on interest on interest payable after 30 June in the calendar year next following that in which the noticeis given.