Tax treaties
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
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
