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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

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 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 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 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 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.
Exclusive PPT: substantial requirements for applying double tax treaty benefits in Mexico
  • Article
  • May 2023
  • Juan José Paullada Eguirao and Fernando Caballero Gout
Juan José Paullada Eguirao and Fernando Caballero Gout of Ritch Mueller discuss the substance requirements for applying double tax treaty benefits in the context of the MLI's Principal Purpose Test.
Exclusive In detail: the UK and Brazil's double tax treaty
  • Article
  • Mar 2023
Brazil's new treaty shows an effort to align tax law with OECD standards, say local lawyers Allan Fallet and Ariene Reis, who list some of the agreement's key provisions.
Exclusive Australia announces important changes to thin capitalisation rules
  • Article
  • Jan 2023
  • Jock McCormack
Jock McCormack of DLA Piper Australia reports on the forthcoming revision of the country's thin capitalisation rules, proposals for a new anti-avoidance rule, and the expansion of double tax treaties.
Exclusive Turkey's DST creates worry and double taxation issues
  • Article
  • Jan 2020
  • Mattias Cruz Cano
Taxpayers are concerned about the lack of detail on Turkey's proposed digital services tax (DST) because it differs significantly from other countries, risking double taxation on cross-border online advertising services and treaty disputes.

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.
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.
Advising British expats: tax compliance and planning, 2023-24
  • Library book
  • 2023
  • J. Connolly
  • Claritax
This book 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. The 2023-24 edition includes a number of updates and additions, addressing topics such as pension transfers to overseas schemes, the new client income record, Making Tax Digital for Income Tax Self Assessment, and changes to the filing of CGT on UK property returns.
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 and Faculties Online subscribers on tax problems for a nominal fee.
Tax Faculty 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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Information

Some of the content on this web page was provided by the Chartered Accountants’ Trust for Education and Research, a registered charity, which owns the library and operates it for ICAEW.