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McKee, Sophie A. Hoquet (1984) A study of the legal effect of the main provisions of the income tax treaty between France and the United Kingdom. Doctoral thesis, City of London Polytechnic.
This thesis is believed to be the first exhaustive work on the 1968 double taxation agreement between France and the United Kingdom. An attempt has been made to provide a comprehensive and thorough analysis of this particular tax convention.
The thesis first investigates matters relevant to all categories of treaties: treaty making power, the relationship between a treaty and domestic legislation and the rules of treaty interpretation. It then proceeds to study the specific structure, nature, scope and function of double taxation agreements.
A comparative approach has been taken to the study of all relevant legal concepts in the field of company and revenue law. An attempt has been made to compare the British and French anti-avoidance legislation relating to international transactions and to draw conclusions as to their respective impact.
The purpose of existence of the double taxation agreement between France and the United Kingdom is to settle the problems of international double taxation. This thesis analyses the taxation rules applicable to different classes of income and the respective rights to tax of both the state of source and the state of residence. Its main objective is to provide an exhaustive explanation of the rules of taxation, together with an illustration of their practical operation. It is hoped that this has been achieved through a systematic analysis of commentaries, articles of doctrine (academic discussion), publications of Revenue authorities and case law.
It is hoped that this work will extend beyond British and French frontiers and that some of the suggestions and recommendations made in it will find a place in a worldwide context. An attempt has been made to make some contribution towards an improvement in the negotiation of double taxation agreements at Government level and an amelioration of their application by taxpayers, tax authorities and jurisdictions.
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