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HMRC internal manual

International Manual

DT applications and claims: Overview of DT Agreements

Content of the DTAs

Although the layout of the agreements is fairly standardised the detailed provisionsvary from agreement to agreement. You should therefore refer to the precise text when you are applying the terms of any DTA to a specific case

The main things which are contained in a DTA are as follows and are usually in the following order

  • the names of the two parties (the Government of each country) involved
  • the taxes in each country. In the UK these are usually income tax (including higher rate tax), corporation tax and capital gains tax. In the other country it is usually the national income tax, and other taxes imposed by the central government. Local and provincial taxes are usually excluded
  • the territories of each country. The ‘United Kingdom’ usually means the United Kingdom of Great Britain and Northern Ireland (this does not include the Channel Islands and Isle of Man). The territory of the other country is usually its Metropolitan territories but occasionally includes dependencies
  • the definition of terms, for example, ‘resident of’ and ‘permanent establishment
  • detailed provisions of the various types of income
  • credit provisions against tax of the country of residence for tax paid in the country where the income arises
  • exchange of information provisions
  • detailed provisions for personal allowances, reliefs and reductions
  • the operative date(s) of the DTA for each country.