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Interpreting tax treaty articles against HMRC guidance
13 July 2021 Julia Ascott, Employment Taxes Specialist
For anyone with Croner-I access, they recently published an article assessing how useful HMRC guidance is when interpreting articles in tax treaties following some recent cases. It mirrors what any tax adviser has probably told you since tax advisers began, the legislation (or in this case, the treaty wording) comes first; HMRC guidance is their interpretation of that legislation/treaty.
For anyone trying to review treaty rules against HMRC guidance, this is an invaluable article, setting out the case law and practical guidance on what commentaries can be relied upon and options where your opinion may differ from HMRC guidance.
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13 July 2021 
Julia Ascott, Employment Taxes Specialist
