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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Isle of Man: Agreements

The agreement (SI1955/1205) has effect

a) In the United Kingdom for

i) Income Tax from 1955-56,

ii) Corporation Tax from 1 April 1964;

b) In the Isle of Man from the year of assessment beginning 6 April 1955.

The agreement was first amended in 1991 (SI1991/2880) to include provisions covering offshore activities (see DT9957).

A second amending agreement (SI1994/3208) introduced provisions as Paragraph 9B which disentitled certain types of companies from relief under the arrangement (see DT9953).

A further amending agreement (SI2009/228) which introduced provisions on pensions and a mutual agreement procedure and amended certain other provisions of the 1955 agreement had effect from 6 April 2009 for income tax purposes and 1 April 2010 for corporation tax purposes.

Although the 1955 agreement does allow for some exchange of information, the United Kingdom also has a tax information exchange agreement (TIEA) with the Isle of Man, which entered into force on 2 April 2009.

Details as to what information can be exchanged can be found in the agreement itself. If using the HMRC Intranet, the agreement can be viewed through the “New treaties/protocols in force” link on the sidebar, following the TIEAs link on the subsequent sidebar. On the HMRC web-site, searching for “TIEAs in force” will provide a link to the agreements page.