The implementing legislation authorises a degree of retrospectivity. Treaties may be given effect by virtue of TIOPA 2010, s. 3(1) if they provide relief for tax:

•for periods before the passing of TIOPA 2010; or

•before the making of the treaty in question.

Provision may also be made for tax sparing in such circumstances as to income which is not subject to double taxation or chargeable gains which are not subject to double taxation under ss 3(2) and 4.

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