Robert Langston outlines their scope and limitations.
This article outlines the scope of double tax treaties and some of the common provisions which can limit their application. The text of all UK tax treaties is available from the HMRC website and (limited) commentary on UK treaties is available in the HMRC’s Double Taxation Relief Manual.
The purpose of a treaty is normally stated to be:
For tax authorities the prevention of fiscal evasion is achieved through exchange of information and mutual assistance in collecting tax liabilities.
For taxpayers treaties can limit the tax which arises on cross-border transactions. For example a treaty may set out that no...
