Income Tax (Trading and Other Income) Act 2005 section 608E

Meaning of "full treaty territory"

Section 608E defines what counts as a "full treaty territory" for the purposes of the rules in Chapter 2A concerning certain overseas income.

• A territory qualifies as a "full treaty territory" only if double taxation arrangements are in place with the UK and those arrangements contain a non-discrimination provision.
• A "non-discrimination provision" is a clause that prevents nationals of one treaty state from facing heavier taxation or related obligations than nationals of the other state in the same circumstances, especially regarding residence.
• The term "national" covers individuals holding the nationality or citizenship of a treaty state, as well as legal entities, partnerships, or associations deriving their status under the laws of that state.
• All three definitions — full treaty territory, non-discrimination provision, and national — apply throughout Chapter 2A whenever those terms are used.