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HMRC internal manual

Oil Taxation Manual

Non-Residents Working on the UK Continental Shelf: Double Taxation Agreements - Other treaty implications

As well as reducing UK tax jurisdiction in the manner outlined in OT41510 a treaty may:

  • Provide rules for computing any profits which might be chargeable to UK tax (see OT42000+).
  • Limit the charge to UK tax on emoluments.
  • Limit the charge to UK tax on income and capital gains relating to certain rights (see OT41000+).