Protocol

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ment: I. Ad Article 2 Paragraph 2 The Icelandic social security charge "Tryggingargjald" shall not be regarded as "taxes on the total amounts of wages or salaries paid by enterprises." II. Ad Article 8 For the purposes of this Article and within the meaning of paragraph 14 of the OECD Commentary (2005) on Article 8, interest on investments directly connected with the operat....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tioned Contracting State with respect to such dividends, interest, royalties, or capital gains is substantially less than the tax generally imposed by such Contracting State on corporate profits; and b) 25 percent or more of the capital of such corporation is held of record or is otherwise determined, after consultation between the competent authorities of the Contracting States, to be ow....