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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: India: double taxation agreement, Memorandum of Understanding on Article 27: Mutual agreement procedure

A Memorandum of Understanding (MOU) between India and the UK was agreed in 2004 regarding all cases under the Mutual Agreement Procedure, which can be accessed via the link below.

UK/India Memorandum of Understanding on Mutual Agreement Procedure cases

It provides that the UK and India will suspend the collection of any amounts of tax, including any related interest or penalties, for any taxable years which are subject to the Mutual Agreement Procedure in the UK/India Double Taxation Convention. This is subject to the provision of a bank guarantee by the taxpayer.