The precise effect of treaties in UK tax law and, in particular, whether treaties can impose or increase a tax liability beyond that provided as a matter of domestic law has been subject to some considerable debate.95 Part of the controversy arises from the manner in which the implementing legislation has been drafted. Section 6(2)(b), for example, authorises that treaties shall ‘have effect’ insofar as they provide:

‘(b)for taxing the income of non-UK resident persons arising from sources in the United Kingdom to persons not resident in the United Kingdom;’

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