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HMRC internal manual

International Manual

Description of double taxation agreements: Description of double taxation agreements: general

The normal form of agreement consists of some 30 Articles and these can conveniently be divided into three sections:

  1. Articles 1-5 deal with the scope of the agreement, the taxes covered, definition of terms, questions of residence and the definition of a permanent establishment.
  2. Articles 6-21 deal with the treatment of income of various descriptions, business profits, dividends, interest, royalties, employment income etc and sometimes capital gains.
  3. The remaining articles are of a general nature and include the provisions for the elimination of double taxation, exchange of information, non-discrimination, entry into force etc.

The following paragraphs describe briefly the contents of each Article. It is again emphasised that these are only general descriptions and the contents of the Articles may vary from one agreement to another.