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Double tax agreements

Expert commentary and practical guidance from ICAEW on issues related to double taxation and the use of tax treaties in international taxation

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Need to know

Finding double tax treaties
  • Research guide
There are thousands of double tax treaties world-wide. The UK has double tax treaties with more than 130 countries, making it one of the world's largest networks. The library team can help you find the treaties you need.
Interpretation and application of double tax treaties
  • Listing
The library collection includes many key works on the interpretation and application of double tax treaties, as well as titles on international tax disputes relating to double tax conventions and strategic tax planning using double tax treaties.
Country resources
  • Hub page
Resources on over 170 countries and territories including economic forecasts, guides to doing business and information on the tax climate in each jurisdiction.

Practical guidance

TAXguide 19/21 Off-payroll working: cross-border issues
  • Technical release
  • 03 Dec 2021
Off-payroll working: guidance on clients’ off-payroll working obligations when a contractor works through an intermediary such as a personal service company across borders and/or some of the parties (client, contractor, contractor’s personal service company) are non-UK resident and/or the work is not wholly carried out in the UK, how the ‘host employer’ rules in s689 ITEPA 2003 interact, and the impact of double tax treaties.

Features and articles

How to avoid errors when claiming double tax relief
  • Article
  • 25 Nov 2024
HMRC has published guidance intended to reduce errors made by dual residents and their agents when claiming double tax relief in the income tax return.
The Taxation (Cross-border Trade) Act 2018
  • Article
  • 04 Oct 2018
The Taxation (Cross-border Trade) Act 2018 received Royal Assent on 13 September 2018.

Bloomsbury Accounting and Tax Service

Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising around 80 titles from some of the country's leading tax and accounting subject matter experts. Find out who is eligible and how you can access the Accounting and Tax Service.
Exclusive The international dimension
  • eBook chapter
  • 2024
  • Rachael Brown
  • Personal Tax Planning
Three chapters providing tax planning advice related to domicile, residence, international tax and double tax relief.
Exclusive International tax and investment service
  • eBook
  • 2024
  • Dennis Campbell
  • International Tax and Investment Service
Country-by-country information on a range of important areas of international tax law, updated by two issues annually.
Exclusive Double tax relief in practice
  • eBook chapter
  • 2023
  • Lynne Oats
  • Principles of International Taxation
A chapter on double tax relief in practice, covering topics including: variations on the credit method, variations on the exemption method and the exemption method in practice.
Exclusive Improper use of treaties
  • eBook chapter
  • 2023
  • Lynne Oats
  • Principles of International Taxation
A chapter exploring some of the most common corporate structures used for the purpose of abusing bilateral tax treaties, as well as the common approaches to preventing such improper practices.
Exclusive Double tax treaties
  • eBook chapter
  • 2023
  • Lynne Oats
  • Principles of International Taxation
A chapter on double tax treaties, covering topics including: their relationship to domestic law, creation of a double tax treaty, the OECD Model Tax Convention and interpretation of tax treaties.
Exclusive Automatic exchange of information handbook
  • eBook
  • 2021
  • John Hiddleston, Azets
  • Automatic Exchange of Information Handbook
A practical guide to the automatic exchange of information rules legislation within the UK, covering the requirements of the OECD Common Reporting Standard (CRS) and the US Foreign Account Tax Compliance Act (FATCA).
Exclusive International tax materials
  • eBook
  • 2017
  • HMRC, Crown copyright
  • International Tax Materials
The full text of UK Double Tax Agreements and other related documents in an A-Z by country format.
Terms of use

You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the Acceptable usage terms.

Industry press

The ICAEW Library & Information Service provides access to a range of leading tax journals. These journals are available to logged-in ICAEW members, ACA students and other entitled users subject to suppliers' terms of use.
Exclusive The demise of the U.S.-Russian tax treaty
  • Article
  • Sep 2024
  • Robert J. Misey, Jr.
This article considers the impact of the termination of the U.S.-Russia income tax treaty on cross-border investors who rely on such treaties to avoid double taxation.
Exclusive Brazil–UK double tax treaty: a new solution to an old riddle?
  • Article
  • Aug 2024
  • Paulo Victor Vieira da Rocha and Murilo Jakuk
Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss treaty articles 12 and 13 within the context of national case law concerning the taxation of fees paid for imported technical services
Exclusive US partially suspends tax treaty with Russia
  • Article
  • Jun 2024
  • Michael Cohn
The US Treasury Department has formally notified Russian authorities that it is partially suspending a tax treaty, as relations between the two countries remain strained.
Exclusive Australian roundup: AusNet decision, South African treaty modifications, and thin capitalisation reforms
  • Article
  • Apr 2024
  • Jason Carli
Jason Carli of DLA Piper Australia analyses a Federal Court ruling on rollover relief, the publication of updates to a double tax agreement, and a report on amendments to the thin capitalisation reform bill.
Exclusive Italy clarifies natural persons' tax residency qualification under tax treaties
  • Article
  • Mar 2024
  • Paolo Ludovici, Ludovica Lorenzetto
The Italian Supreme Court has ruled that a natural person does not need to be actually subject to individual income tax to receive tax treaty protection, report Paolo Ludovici and Ludovica Lorenzetto of Gatti Pavesi Bianchi Ludovici.
Exclusive US-Hungary tax treaty no longer in effect
  • Article
  • Jan 2024
  • Michael Cohn
The double taxation treaty between the U.S. and Hungary has been terminated as of 1 January 2024.
Exclusive Australian thin capitalisation reforms delayed and subject to further review
  • Article
  • Oct 2023
  • Jock McCormack
Jock McCormack of DLA Piper reports on proposed revisions to Australia's new thin capitalisation reforms, and discusses the country's expanding double tax treaty network.
Exclusive UK hints at retaliation against Russia over tax treaty suspension
  • Article
  • Sep 2023
Russia suspended 38 tax treaties in response to the EU blacklisting the country after the 2022 invasion of Ukraine.

Articles and books in the ICAEW Library collection

The collection of the ICAEW Library & Information Service includes a range of articles, books and reports on double tax agreements. A selection of books on this topic is set out below.
Advising British expats: tax compliance and planning, 2024-25
  • Library book
  • 2024
  • J. Connolly
  • Claritax
This annual work provides in-depth coverage of residence, domicile, and double taxation matters, focusing on how UK taxes (such as income tax, CGT, NIC, IHT, etc.) impact expatriates.
Double tax treaties: a practical introductory guide
  • Library book
  • 2024
  • J. Bennett
  • LexisNexis
A brief Tax Digest on double taxation treaties. It outlines key concepts (such as beneficial ownership, permanent establishment, and residence), examines selected distributive and relief provisions, and considers the application of double tax treaties to cross-border transactions.
An essential guide to withholding tax
  • Library book
  • 2024
  • A. Collinson
  • LexisNexis
A brief digest examining withholding tax. Covers withholding tax on yearly interest, withholding tax on royalties and other payments relating to intangibles, withholding tax on fees for technical services, double tax agreements, EU directives of relevance to withholding tax, and US withholding tax rules.
Tolley's international tax planning, 2023-24
  • Library book
  • 2023
  • A. Seidler, I. Butt, D. Nott
  • LexisNexis
This book sets the UK tax system in the context of international treaties and the international legal framework, examining issues such as permanent establishment, hybrids, EU law, thin capitalisation, interest deductions, withholding taxes, transfer pricing and information exchange. It includes a summary of the OECD's work on Pillar One and Pillar Two, along with a detailed treatment of the UK's implementation of Pillar Two. Examples, tables and checklists are included to aid understanding.
Principles of international taxation, 9th ed.
  • Library book
  • 2023
  • L. Oats
  • Bloomsbury Professional
This book provides a clear introduction to international taxation. It covers policy, legal issues and planning points, primarily from the viewpoint of a multinational group of companies. Examples and diagrams are given throughout.
The Oxford handbook of international tax law
  • Library book
  • 2023
  • F. Haase, G. Kofler (eds.)
  • Oxford University Press
This handbook traces the history of international tax law from its earliest days until the present. It includes coverage of the key issues in this area today, including tax transparency, minimum corporate taxation, the tackling of Base Erosion and Profit Shifting (BEPS), and the reconstruction of the network of bilateral tax treaties.
Studies in the history of tax law, volume 10
  • Library book
  • 2023
  • P. Harris, D. de Cogan (eds.)
  • Hart Publishing
A collection of papers presented at the tenth Tax Law History Conference, held on 20th July 2020. Topics covered include the initial income tax period, the impact of the two world wars on the UK's tax law, the history of UK capital gains tax, and historical double tax agreements.
Schwarz on tax treaties, 6th ed.
  • Library book
  • 2021
  • J. Schwarz
  • Kluwer Law International
This book provides an analysis of UK and Irish tax treaties, considering the interaction of those treaty networks with EU and international law, as well as with national tax rules, administrative law and constitutional rules.

To find out how you can borrow books from the Library please see our guide to borrowing books.

You can obtain copies of articles or extracts of books and reports through our document supply service.

External resources

Some resources that we link to may pre-date the latest amendments to the relevant tax regulations. While these links contain useful information, please treat them with appropriate caution.

Deloitte International Tax Source: Treaty rates
  • Website
  • Deloitte
Online tool that allows users to select from 66 jurisdictions worldwide and compare double tax treaty rates for dividends, interest and loyalties.
History of Tax Treaties Data Base
  • Website
  • taxtreatieshistory.org
Database providing historical documents relating to treaties drafted under the OECD Model Convention of 1963 and the older convention drafted under the League of Nations.
Tax treaties on GOV.UK
  • Website
  • HMRC
Official listing of double tax treaties between the UK and other countries. It includes treaties that have been signed but are not yet in force.
Mutual Agreement Procedure
  • Website
  • UK Government
Statement of Practice from HMRC outlining the process for the Mutual Agreement Procedure and the use of MAP under the relevant UK Double Taxation Agreements and/or the EU Arbitration Convention (EUAC).
Double Taxation Treaties: non UK resident with UK income
  • Website
  • HMRC
Digest of current double tax agreements showing available relief for non-residents of the UK on sources of UK income, covering dividends, interest, royalties, annuities and allowances.
Resolution of double taxation disputes in the European Union
  • Website
  • European Commission
Summary of the new rules intended to help taxpayers seeking resolution of problems relating to the interpretation of tax treaties.
International Manual
  • Website
  • UK Government
Internal manual from HMRC covering international tax issues including the principles of double taxation relief and an introduction to double taxation agreements
Disclaimer

ICAEW accepts no responsibility for the content on any site to which a hypertext link from this site exists. The links are provided ‘as is’ with no warranty, express or implied, for the information provided within them. Please see the full copyright and disclaimer notice.

Further support

TAXconnect
  • Listing
  • 06 Mar 2015
Search for a consultant to help you with a specific technical tax problem. TAXconnect works on a telephone ‘hotline’ system, whereby consultants offer advice to fellow Tax Faculty members on tax problems for a nominal fee.
Tax Faculty
  • Hub page
  • 10 May 2018
Find out more about the Tax Faculty and upcoming events. Faculty members can access exclusive content, including TAXline, TAXguides, webinars, representations and support schemes.
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