Brazil and San Marino tax agreements given effect

The Treasury has published the following two orders which give effect to new UK double taxation agreements with Brazil and San Marino:

• Double Taxation Relief and International Tax Enforcement (Brazil) Order, SI 2023/839 that gives legislative effect in the UK to the 2022 UK-Brazil double taxation convention, and to earlier arrangements that apply to taxation of profits from shipping and air transport which apply retrospectively and will be superseded by the 2022 agreement when it comes into force; and
• Double Taxation Relief and International Tax Enforcement (San Marino) Order, SI 2023/841, that gives effect in the UK to the 2023 UK-San Marino double tax convention.

Both new agreements are based on the OECD's model tax convention on income and capital, with specific adaptations where necessary.