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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: France: Channel Tunnel provision

Article 9 of the agreement covers the taxation of profits and emoluments linked to the Channel Tunnel. Very broadly it ensures that the taxation of the Channel Tunnel Group Ltd and its French counterpart, France-Manche SA, their holding companies (Eurotunnel plc and Eurotunnel SA), and associated companies, so long as the current arrangements set out in the Channel Tunnel Treaty remain in being, is as follows:

  • the profits derived by each company are taxable only in their state of residence
  • the remuneration of their employees from employments on the Tunnel exercised in both contracting states may be taxed in the state in which the effective management of the employer is to be found notwithstanding the terms of Article 15 (the employment article which is in the usual form).