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Commentary

6.2.2 Treaty relief

United Kingdom

The UK has several double tax agreements which can be found at GOV.UK. Note that the UK considers that the double tax agreements with Russia and Belarus remain in force despite their unilateral suspensions by Russia and Belarus. HMRC has indicated that the UK is continuing to comply with the terms of the agreements with Russia and Belarus.

Treaty Article 4 usually deals with residence. The dependent services article/employment income article (usually Article 15) deals with taxation of employment income where domestic law would otherwise result in a charge to income on the same income in both countries.

It is important to note that tax applied under the domestic law of the country may not be subject to the terms of a double tax agreement (DTA). A liability could arise due to differing tax charges and differing classifications of income. It is important to read the relevant treaty carefully.

The first part of the treaty employment article gives

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