Part 2Double taxation relief
CHAPTER 1Double taxation arrangements and unilateral relief arrangements
Double taxation arrangements
3Arrangements may include retrospective or supplementary provision
(1)
Section 2(1) gives effect to arrangements even if the arrangements include—
(a)
provision for relief from tax for periods before the passing of this Act, or
(b)
provision for relief from tax for periods before the making of the arrangements.
(2)
Section 2(1) gives effect to arrangements even if the arrangements include—
(a)
provision as to income that is not subject to double taxation,
(b)
provision as to chargeable gains that are not subject to double taxation, F1...
(c)
provision as to foreign-field consideration that is not subject to double taxation F2or
(d)
provision conferring (with or without other functions) functions relating to the determination of matters arising under the arrangements on a public authority in the United Kingdom or in a territory outside the United Kingdom.
(3)
In subsection (2)(c) “foreign-field consideration” means consideration brought into charge to tax under section 12 of the Oil Taxation Act 1983 (charge to petroleum revenue tax on consideration in respect of United Kingdom use of a foreign field asset).