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HMRC internal manual

International Manual

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

Agreements may require revision from time to time. This may be when there is a substantial change in the taxation laws of either the United Kingdom or the other country, or because of changes in the balance of economic relations between both countries or because of particular needs of business. Revision of agreements may take two forms, either a re-negotiation of the whole agreement or the negotiation of an amending protocol. Agreements should be read together with any amending protocols.