SCHEDULEPROTOCOL

ARTICLE II

2

This Protocol shall enter into force on the date of the receipt of the later of these notifications and shall there upon have effect:

a

in the United Kingdom:

i

in respect of income tax, for any year of assessment beginning on or after 6th April 1994;

ii

in respect of corporation tax, for any financial year beginning on or after 1st April 1994;

b

in the Republic of Ireland:

i

in respect of income tax, for any year of assessment beginning on or after 6th April 1994;

ii

in respect of corporation tax, for any financial year beginning on or after 1st April 1994.