OT41530 - 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 바카라 사이트渞estricted definition바카라 사이트� of 바카라 사이트渢he UK바카라 사이트�, that is those which define 바카라 사이트渢he UK바카라 사이트� in such a way as to exclude the UK Continental Shelf.
  2. Those which have an 바카라 사이트渆xtended definition바카라 사이트� of 바카라 사이트渢he UK바카라 사이트� (by including the UK Continental Shelf) but do not have an Offshore Activities Article (see below).
  3. Those which have an 바카라 사이트淥ffshore Activities Article바카라 사이트� (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 바카라 사이트渆xtended definition바카라 사이트� 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 .