Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Double tax treaty definition

What does Double tax treaty mean? A double tax treaty (DTT) is a bilateral agreement between two states that determines which country may tax cross‑border income and how double taxation is relieved in practice. Typically modelled on the OECD Model Tax Convention, a DTT sets rules for tax residence and permanent establishment, allocates taxing rights over business profits, employment income, pensions, dividends, interest, royalties and many capital gains, and limits withholding tax rates. Relief is usually provided by exemption or credit, supported by non‑discrimination, exchange of information and a mutual agreement procedure; modern treaties also include anti‑avoidance measures (for example, a principal purpose test,...

UK real estate: double tax treaty relief for non‑UK investors on rental income, REIT PIDs, and gains from direct and indirect disposals

Published by a LexisNexis Tax expert

Practice notes

A significant share of those investing in UK property reside outside the UK. The British real estate market appeals to a broad and diverse spectrum of Investors, from high net worth individuals buying premium residential assets to international funds placing capital into London office space or out-of-town shopping centres across the UK. Typically, such investors seek to organise their investment so that:

as far as possible, they do not fall within the scope of UK taxation, namely:
- for companies—corporation tax on income and chargeable gains
- for individuals and trusts—income tax on trading income, capital gains tax (CGT) and Inheritance tax
to the extent any UK tax does arise, they are entitled to double tax relief

Accordingly, investors will often aim to invest from outside the UK and, where appropriate, to obtain relief under double tax treaties (DTT) concluded between the UK and the jurisdiction in which they are resident (the state of residence). The provisions of DTTs entered into by the UK with other states take effect under UK domestic law by virtue of section 2 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010) (and, more generally, Part 2)...

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Charles Goddard

Rosetta Tax

Charles is a solicitor at Rosetta Tax Limited, which specialises in corporate tax advice to businesses and professional services firms. He has a broad range of tax advisory expertise, having acted for a variety of UK-based and international financial institutions and listed companies. He has particular expertise in the real estate and finance sectors, with a strong focus on the taxation of insolvency and restructuring transactions.Charles was for six years until 2012 a tax partner at Berwin Leighton Paisner LLP. Prior to joining BLP, he spent eight years at Slaughter and May as a trainee and associate in their Tax group. He is recommended by both Chambers and Partners and Legal 500....

Web page updated on 22/05/2026

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