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Vol 23 No 3 March/April 2018

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UK Tax Treaties

ISBN13: 9781405755290
Published: February 2013
Publisher: LexisNexis Butterworths
Country of Publication: UK
Format: Paperback
Price: £163.12

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UK Tax Treaties considers the practical interpretation of the UK's double tax treaties and domestic rules concerning relief from double taxation, as they relate to the taxation of income in the UK on both UK resident and non-UK resident companies.

The work also discusses, article by article, the OECD and UN model treaties and commentary, covering key case law surrounding the interpretation of double tax treaties.

Also contained in the text is a chapter dealing with key EU treaty matters as they relate to UK corporation tax.

Featuring over 100 worked examples, this comprehensive work focuses on the practical application of the UK domestic and treaty law, as well as containing coverage on royalties, licence payments, permanent establishment and much more, allowing the practitioner to give more succinct transactional advice.

1. Introduction
2. Historical background to double tax relief and treaties
3. UK domestic rules (income)
4. UK domestic rules (capital gains)
5. UK domestic rules (distributions)
6. UK domestic rules (non-residents)
7. Special companies (e.g., financial traders)
8. Background to treaties and OECD/UN models/commentary
9. Articles in agreements - scope and definitions (e.g. PE)
10. Articles in agreements business profits
11. Articles in agreements - associated enterprises
12. Articles in agreements shipping and air transport
13. Articles in agreements - dividends, interest and royalties
14. Management fees
15. Capital gains
16. Independent personal services
17. Dependent personal services
18. Directors' fees
19. Artists and athletes
20. Pensions and annuities
21. Government service
22. Professors, teachers, students and apprentices
23. Income not expressly mentioned/other income
24. Capital
25. Non-discrimination
26. Mutual agreement
27. Exchange of Information
28. Territorial extension
29. Entry into force/termination
30. Treaty shopping and other avoidance
31. EU Treaty matters