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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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USA: double taxation agreement, Article 13: Capital gains

Replaced by new DTA, which applies in UK from 1st April 2003 for CT, 6th April 2003 for IT and 1st January 2004 for PRT. For US withholding taxes it applies from 1st May 2003 and for other US taxes from 1st January 2004. See DT19939C.

Except as provided in Article 8 (Shipping and air transport) of this Convention each Contracting State may tax capital gains in accordance with the provisions of its domestic law.