Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 130: Interpreting provision about UK taxation of profits of foreign enterprises

278.This section ensures that a specific provision commonly found in DTAs (that is designed largely to limit the rights of the States to tax the business profits of residents of the other State) cannot be read as preventing the income of UK residents being charged to United Kingdom tax. It is based on section 815AZA of ICTA.

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