Aim of

Avoidance and abuse of law

Benefits

Binding upon parties

Charging income or gains

Compensation for breach of European law

Construction principle

Definition of treaty

Discrimination

Authorising discrimination

Generally

Neutralising

Distributive provisions

Domestic law

Double taxation abolition

Draft

Effect

Generally

Limits on

Entry into force

Estates, inheritance and gift tax

European law

– see European law

Extension of treaty benefits

Impact of European law

Implementation

Domestic law

Generally

International law

Scope of

Incorporation into domestic law

Interpretation

Law of

Limiting access to treaty benefits

Non-discrimination provisions

Non-residents

Tax credits

Treaty benefits

Non-treaties

Generally

Tax rules

Observance of

Old law, made under

Overriding provisions

Pacta sunt servanda principle

Power to make

Precedence over domestic law

Procedure for making

Putative

Ratification

Relationship with specific statutory provisions

Relief from income or corporation tax

Restrictions

Defences to

Effect on

Retrospective effect

Revocation

Role of

Scope of

Sovereignty, changes in

State succession

Tax credits for non-residents

Taxes covered

Temporal scope

Termination

Territorial scope

Third countries

Distinction between member states and

EU treaties with

Generally