83 Resolution of double taxation disputes

International agreements

83  Resolution of double taxation disputes

In Chapter 2 of Part 2 of TIOPA 2010 (double taxation relief: miscellaneous provisions) after section 128 insert—

“International dispute-resolution instruments and agreements
128A Power by regulations to give effect to international obligations etc

(1)     The Treasury may make regulations for, or in connection with, giving effect to or enabling effect to be given to—

(a)     Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union (“the Directive”);

(b)     any instrument modifying or supplementing the Directive;

(c)     any international agreements or arrangements that deal with—

(i)     matters dealt with by the Directive,

(ii)     matters that are similar to any of those dealt with by the Directive, or

(iii)     any other matters that relate to or are connected with the resolution of disputes in relation to double taxation arrangements.

(2)     The provision that may be made by regulations under this section includes (in particular)—

(a)     provision as to the effect of any arrangements that the Commissioners for Her Majesty's Revenue and Customs may make with authorities of territories outside

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