SSPEs shall not be established in a country or territory outside the United Kingdom to which any of the following applies:

(a) the country or territory is listed as a high-risk and non-cooperative jurisdiction by the FATF;

(b) the country or territory has not signed an agreement with the United Kingdom to ensure that that country or territory fully complies with the standards provided for in Article 26 of the Organisation for Economic Cooperation and Development (OECD) Model Tax Convention on Income and on Capital or in the OECD Model Agreement on the Exchange of Information on Tax Matters, and ensures an effective exchange of information on tax matters, including any multilateral tax agreements.