Article 2 Double taxation agreement to have effect

the agreement set out in the Schedule to this Order has been made with the Government of the Federative Republic of Brazil;

the agreement has been made with a view to affording relief from double taxation in relation to income tax and taxes of a similar character imposed by the laws of the Federative Republic of Brazil, derived by a member of the crew of an aircraft operated in international traffic; and

it is expedient that the agreement should have effect.