Double taxation relief

Double taxation relief guidance:

What are the anti-avoidance concerns in a double tax treaty context? As discussed in Practice Note: What are double tax treaties?, one of the aims of double tax...

Practice Note

Why is assistance in collection needed? The background to this topic is the existence of a general rule of international law concerning the fact that generally one...

Practice Note

FORTHCOMING CHANGE relating to UK property business and non-UK resident companies: From 6 April 2020, non-UK resident companies will be brought into the charge to...

Practice Note

Article 10 of the OECD model convention is concerned with the taxation of dividends paid cross border. In particular it deals with the allocation of taxing rights...

Practice Note

International tax law is mostly concerned with the taxing rights of states. As with all forms of international law, the need to deal with such issues arises from...

Practice Note

Article 11 of the OECD model convention is concerned with the taxation of interest paid cross border. In particular, it deals with the allocation of taxing rights...

Practice Note

This Practice Note explains some of the key definitions and concepts a tax lawyer will come across when dealing with a double tax treaty or double tax convention (DTT),...

Practice Note

Double tax treaties or conventions (DTTs) have a dual nature. They are: • conventions between states (the contracting states), governed by international law, and • part...

Practice Note

Article 12 of the OECD model tax convention (OECD model convention) is concerned with the taxation of royalties paid cross-border. In particular it deals with the...

Practice Note

Unilateral relief may be available as a credit against UK inheritance tax (IHT) where a tax of a character similar to IHT has been imposed on property in an overseas...

Practice Note

Double tax treaties (DTTs) allocate taxing rights between jurisdictions, with the primary aim of ensuring that taxpayers do not suffer tax on the same income twice in...

Practice Note