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HMRC internal manual

International Manual

HM Revenue & Customs
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Double taxation agreements: introduction: Negotiation of agreements

The Commissioners for HM Revenue and Customs are responsible for the negotiation of the terms of agreements, subject to ministerial approval. Once the draft agreement is agreed by the representatives of both countries they initial the draft. The final text is subsequently signed on behalf of both countries and in the United Kingdom is then laid before the House of Commons in the form of a draft Statutory Instrument. When approved, it receives the Royal Assent by Order in Council (TIOPA10/S2).

Each country has to notify the other that it has done everything necessary to give the agreement the force of law and only when each country has done so does the agreement come into force. In the UK, taxpayers have no rights under the agreement itself; the rights arise under the Statutory Instrument and the legislation which gives the agreement the force of law (CIR V Collco Dealings Ltd 39TC509).