FTT confirms consortium relief ownership proportion based on collective entitlement of link com...
Tax analysis: In Eastern Power Networks plc and others v HMRC, the First-tier Tax Tribunal (FTT...
A double tax treaty, agreement or convention (referred to here as DTTs) is:
an agreement
between two states (known as bilateral agreements) or, more rarely, between more than two states (known as multilateral agreements)
usually to deal with:
the allocation of taxing rights between the two (or more) states (known as contracting states) over income and gains (and in certain DTTs other areas such as estates on death), and
the prevention of avoidance and evasion of tax cross-border
The majority of DTTs are based on one of the international model conventions produced by:
the Organisation for Economic Co-operation and Development (OECD)
the United Nations (UN), or
the US
DTCs are generally structured in a similar way in three main parts:
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