Structure of a tax treaty

Copyright © 2026 LexisNexis
Produced by a Tolley Personal Tax expert
Personal Tax
Guidance

Structure of a tax treaty

Copyright © 2026 LexisNexis
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 Cooperation 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 see what

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  • 23 Feb 2026 10:10

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