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HMRC internal manual

International Manual

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HM Revenue & Customs
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Description of double taxation agreements: Excluded persons

Some of the UK’s treaties exclude from the treaty certain categories of persons that are exempted, or taxed only at nominal rates, under the other country’s legislation. Granting them the benefits of the treaty may be regarded as inappropriate since they are suffering little if any double taxation. And, by doing so, might possibly create opportunities for abuse. There is no equivalent of this Article in the OECD Model Double Taxation Convention.

The following are treaties which contain an Article excluding certain types of person;

Cyprus,

Guernsey,

Isle of Man

Jersey,

Malaysia

Malta

The following are treaties which contain an Article excluding certain types of company;

Antigua,

Barbados,

Jamaica

Luxembourg

Where necessary the treaty should be consulted in order to determine what benefits are denied.