E6.411 Treaty Relief—Authority For Double Taxation Agreements

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Commentary

Personal and employment tax

His Majesty may declare by Order in Council that a double taxation agreement with a foreign territory is to have effect¹. Such an Order is subject to prior approval by the House of Commons². A similar procedure is laid down for IHT agreements³. In the UK agreements take their authority from the fact that they are contained in statutory instruments.

UK agreements operate with the foreign territory and its 'authorities' as opposed to the government of the foreign territory. This ensures that a double taxation agreement can still take effect even if the UK does not recognise the government of a particular territory, such as Taiwan.

Agreements, arrangements and conventions

The

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