Taxation (International and Other Provisions) Act 2010 section 7

General regulations

Section 7 grants HMRC a broad power to make regulations for implementing the provisions of double taxation arrangements and the related treaty sections of the Act.

• HMRC may make regulations to carry out the treaty sections of the Act or any double taxation arrangements with other territories.
• Regulations may specifically prevent tax relief under a double taxation arrangement from benefiting persons who are not entitled to it.
• Where tax was not deducted from a payment in reliance on a double taxation arrangement, but it later turns out the arrangement did not apply, regulations may authorise HMRC to recover that tax by assessment on the recipient or by deduction from later payments.
• These regulation-making powers do not apply to petroleum revenue tax or to foreign taxes that resemble petroleum revenue tax rather than income tax, corporation tax or capital gains tax.