Although there is generally no limit on what may be agreed in a treaty, the implementing legislation may not give full effect to treaties that are authorised under TIOPA 2010, s. 2. The extent to which treaties have effect is not described identically in relation to all taxes. In relation to income tax and corporation tax, for example, TIOPA 2010, s. 6(2) prescribes that treaties shall have effect ‘so far as’ they provide for the items enumerated in that provision.

This language restricts the effect of the treaty in domestic law to those items. The items to which treaties may have effect in relation to income and corporation tax are:

(a)relief from income tax or corporation tax;

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