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HMRC internal manual

International Manual

Double taxation agreements: introduction: UK agreements

All the United Kingdom’s agreements entered into since the publication of the OECD model have been based on this model with appropriate variations to take into account, where necessary, the differing economic circumstances, tax and legal systems of the two countries.

There are still in force a number of agreements, mainly with the UK’s former colonies, which were entered into before the OECD model was published.

INTM153010 onwards describes the principal Articles in the majority of the UK’s double taxation agreements. These paragraphs are only intended to be of a general nature and it is important that the text of the agreement with the country concerned should be carefully examined to see what, if any, departures there are from the general pattern. The text of double taxation agreements which have entered into force most recently is available on the International internet site. The text of all earlier comprehensive double taxation agreements is included in the Double Taxation Relief manual.