Structure of a tax treaty

Produced by a Tolley Personal Tax expert
Personal Tax
Guidance

Structure of a tax treaty

Produced by a Tolley Personal Tax expert
Personal Tax
Guidance
imgtext

Where foreign income, gains and profits are concerned, the provisions of double tax treaties are very important. This guidance note outlines what to expect in a treaty, and some of the common points that may need to be considered. The focus of this guidance note is how tax treaties might apply to individuals.

The UK has over 100 treaties. For the current list, see the GOV.UK website. Most use the Organisation for Economic Co-operation and Development (OECD) model treaty as a template, and tend to follow the same format. However, some treaties are very different from the OECD model, and all are individually negotiated, so that the terms can vary considerably.

For HMRC guidance on double tax treaties and double tax relief, see INTM150000.

Key definitions

There are key terms to look out for in every treaty. The main ones are:

  1. •

    the persons within the scope of the treaty (usually Article 1). Normally the treaty covers persons resident of one state, or dual residents. Also look at the ‘general definitions’ section (usually Article 3) to

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+™
  • 25 Jun 2026 15:30

Popular Articles

Enterprise investment scheme tax relief

Enterprise investment scheme tax reliefOverview of EIS tax reliefsThe enterprise investment scheme (EIS) offers significant tax reliefs to encourage individuals to invest money in qualifying shares issued by qualifying unquoted companies. The scheme is designed to encourage investment in small,

Read more Read more

Loans provided to employees

Loans provided to employeesEmployers sometimes provide their employees with loans, sometimes charging interest and often not, either as part of the reward package or to help the individual meet significant expenditure. For example, it is common to provide loans for the purchase of annual travel

14 Jul 2020 12:11 | Produced by Tolley Read more Read more

Special rate pool and long life assets

Special rate pool and long life assetsSpecial rate poolExpenditure on some types of plant or machinery must, if neither annual investment allowance (AIA) nor first year allowances (FYAs) are available, be allocated to a ‘special rate pool’. Expenditure to be allocated to the special rate pool

14 Jul 2020 13:41 | Produced by Tolley Read more Read more