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HMRC internal manual

International Manual

Description of double taxation agreements: Dates of entry into force

This Article sets out the dates on which an agreement enters into force. Either it is ratified by both parties and it enters into force after the expiration of a certain period or each country notifies the other that it has done all that is necessary to give it effect under its own domestic law and it enters into force on the date of the later of the two notifications.

The Article also specifies the dates on which the agreement is to have effect. In the United Kingdom these dates will be the beginning of a year of assessment for Income Tax or Capital Gains Tax and the beginning of a financial year for Corporation Tax.

If the agreement replaces an existing agreement, this Article will normally provide that if a provision in the old agreement gives greater relief than that given under the new agreement, then the old provision will continue to apply for a certain limited period.