Commentary on Sections Overview Overview
28.This Chapter contains the main general provisions concerning DTAs and unilateral relief arrangements.
29.In Part 18 of ICTA, DTAs are given the colourless label “arrangements” (see section 792(1) of ICTA) and unilateral relief is presented as a relief which is given under hypothetical “arrangements” (see section 790(1) of ICTA). But tax professionals commonly refer to “arrangements” having effect by virtue of section 788 of ICTA as, specifically, “double taxation arrangements”, and this convenient usage has been adopted in this Act. This Part rewrites the unilateral relief provisions as provisions for relief under “unilateral relief arrangements”. Accordingly, in Chapter 2 of this Part “the arrangements” is used without qualification to refer to a DTA or, as the case may be, unilateral relief arrangements for a territory outside the United Kingdom. This approach means that there is no need to rewrite section 790(2) of ICTA (definition of “unilateral relief”). It is repealed without replacement.
30.Sections 2 to 7 deal with DTAs. Sections 8 to 17 deal with unilateral relief arrangements.