Commentary

A6.1203 Double taxation agreements

Administration and compliance

A6.1203 Double taxation agreements

A6.1203 Double taxation agreements

The standard OECD double taxation agreements aim to eliminate the double taxation of income or gains paid in one country by the residents of another. Some agreements also include provision for the exchange of information between tax authorities, generally for the carrying out of 'the provisions of the convention'. Many also extend to cover information exchanges:

'to prevent fraud and facilitate the administration of statutory provisions against legal avoidance,'

and these are a useful source of information for HMRC.

Disclosure of information obtained from another country under the terms of the article is restricted and can be used only

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