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....voidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed that the following provisions shall form an integral part of the Agreement: 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.&quo....

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....), 11 (interest), 12 (Royalties and Fees for Technical Services), or 13 (Capital Gains) if: a) By reason of special measures, the tax imposed on such corporation by the first-mentioned 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 per cent or ....