UK Tax Treaties

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Commentary

Written by specialists in the field to provide a detailed explanation of the impact on UK double tax treaties and UK domestic law on double taxation relief.

The book starts with an introduction to tax treaties, including the approach to their interpretation in the context of UK tax law. A detailed examination then follows article by article basis of the latest standard OECD model convention along with a comparison with the UN model convention latest revised in 2012.

This part of the book deals with some of the key practical issues arising in the UK in the application of specific articles of double taxation treaties. It includes aspects of HMRC practice and cross-refers to the UK case law on tax treaties (and some of the case law from other countries as well where this may be relevant).

Chapter 3 of the book widens the focus to the impact of European Union law on relief from double taxation in a cross-border context and includes a discussion of the key aspects of related European Union legislation and case law.

The remaining chapters of this book discuss double taxation relief under UK domestic law covering situations where credit relief continues to be relevant. It also explores situations where the UK’s now more territorial approach to taxation applies, following the recent reform by the UK Government of the taxation of foreign profits, in particular the distribution exemption and the foreign branch exemption. The focus of these chapters is mainly on the position of companies, although some commentary is included in relation to other categories of taxpayer.


SOURCE CURRENCY:
1st Edition, up to date to December 2012

Contributors

Alastair Munro , BA (Oxon), CTA Author