(Section 2)
1. Application
(a) The provisions of the Convention and Protocols incorporated in Schedule 1 to this Order shall apply as modified below—
(1) as if the contracting parties were Saint Lucia and the Government of the United States; and as if the tax concerned in the case of Saint Lucia were Income Tax;
(ii) as if references to the date of signature were references to the 3rd day of December, 1958;
(iii) as if references to the 6th day of April were references to the 1st day of January.
(b) The extension shall have effect in Saint Lucia as respects tax for the year of assessment next following that in which the last of those measures shall have been taken in the United States and Saint Lucia necessary to give the extension the force of law in the United States and Saint Lucia and for subsequent years of assessment and will have effect in the United States as respects United States tax for the taxable year beginning on or after the 1st day of January in that next following calendar year.
2. Modifications
(a) In Article VI(2) the words “exempt from United Kingdom Surtax” shall be understood for the purposes of this extension as though they read “is not liable to any tax in the territory other than tax imposed with respect to the profits or earnings of the corporation out of which such dividends are paid”.
(b) In Article IX(2) the words “shall be exempt from United Kingdom surtax” shall be understood for the purposes of this extension as though they read “is not liable to tax in the territory at a rate in excess of the rate applicable to a company”.
(c) Articles VII, XIV and XVI shall be deemed to be deleted.