INTM412090 | Transfer pricing: legislation: rules: exemptions: SME - list of treaties with appropriate double taxation article

Below is a list of the double taxation treaties that HMRC regards as containing an appropriate non discrimination article as at 1 April 2024. See INTM412080 for more detailed guidance.

Note - although the double taxation agreements with Jersey and Guernsey contain an non-discrimination article they do not satisfy the criteria of a ‘qualifying territory’. The legislation covering the meaning of ‘qualifying territory’ requires that the non-discrimination provision effects a ‘national of a state’. The term state cannot apply to a Crown Dependency therefore agreements with these territories are not capable of meeting the legislative requirements of a ‘qualifying territory’”.