Taxes Consolidation Act 1997 section 827

Application to corporation tax of arrangements made in relation to corporation profits tax under old law

Section 827 provides that pre-1976 double taxation arrangements which refer to the former corporation profits tax are to be read as applying to corporation tax.

• Old tax treaties made before 31 March 1976 that refer to corporation profits tax are treated as applying to corporation tax and to income and chargeable gains within the charge to corporation tax.
• These treaties apply to corporation tax in the same way as they were expressed to apply to corporation profits tax, and not as they apply to income tax.
• This transitional reading is subject to any express amendments made by the Corporation Tax Acts and to any arrangements made on or after 31 March 1976 that provide otherwise.
• The section does not affect Revenue's power to disclose information under section 826(7) or the procedures for foreign tax credit claims and appeals under paragraph 12 of Schedule 24.