Article 2 Article 2

The Governments of the Contracting States shall notify one another, through diplomatic channels, of the completion of the procedures required by their laws for the bringing into force of this Protocol. This Protocol shall enter into force on the date of the later of these notifications and shall thereupon have effect:

(a)

in the United Kingdom:

(i)

in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6th April 2003;

(ii)

in respect of corporation tax, for any financial year beginning on or after 1st April 2003;

(b)

in Mauritius:

(i)

in respect of income tax, for any year of assessment beginning on or after 1st July 2003;

(ii)

in respect of capital gains tax (morcellement) for any financial year beginning on or after 1st July 2003.