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HMRC internal manual

Oil Taxation Manual

Taxation of Non-Residents under Section 830 ICTA 1988: Double Taxation Agreements - Different types of treaties

Treaties may be divided into 3 broad categories:

  1. Those which contain a “restricted definition” of “the UK”, that is those which define “the UK” in such a way as to exclude the UK Continental Shelf.
  2. Those which have an “extended definition” of “the UK” (by including the UK Continental Shelf) but do not have an Offshore Activities Article (see below).
  3. Those which have an “Offshore Activities Article” (that is an Article which deems certain offshore activities to be carried on through a UK permanent establishment). Treaties with such an Article have an “extended definition” of the UK.

The way in which treaties in each category may affect the scope of charge to UK tax is described in OT41540 to OT41560. As there are often subtle differences between treaties, reference to an agreement is always necessary when considering its effect. A list of the treaties in each of the three categories can be viewed by clicking on the link here (Word 100KB).