A treaty is ‘an international agreement concluded between states in written form and governed by international law, whether embodied in a single instrument, or in two or more related instruments and whatever its particular designation’.10 Thus, although in UK tax treaty practice particular treaties may be labelled as ‘agreements’, ‘conventions’, ‘arrangements’ or otherwise, they are, in effect, treaties under international law. In modern treaty practice, the expression includes, in particular, agreements, conventions, declarations and protocols.

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