The importance of bilateral income tax treaties cannot be underestimated in the international shipping market-place. Indeed, the use of bilateral income tax treaties to obtain an exemption from the double taxation of shipping profits is a necessity in structuring international shipping operations. Accordingly, the information provided in Double Taxation Relief For Shipping is essential to lawyers, accountants and businessmen in the international shipping arena.

Ralph Newns and Sheila Parrington have done an excellent job in compiling the provisions relevant to international shipping operations which are contained in 93 double taxation agreements to which the United Kingdom is a party. (Two of these Agreements, those between the United Kingdom and each of St. Lucia and St. Vincent and the Grenadines, have now been terminated.) The double taxation agreements in effect are reproduced in the form in which they have effect as of 6 April 1988 and subsequent developments between 6 April and 1 May 1988 have been noted.

The authors have reproduced pertinent paragraphs and articles of the United Kingdom’s double taxation agreements which govern such concepts and topics as the taxes covered by the agreements, residence, capital gains, exchange of information, non-discrimination, mutual assistance, and entry into force, as well as the provision directly governing the taxation of profits derived from international shipping operations. In addition, the relevant provisions of Capital Tax Agreements (i.e., inheritance or estate tax) between the United Kingdom and each of 10 foreign countries are also reproduced. The countries with which the United Kingdom has separate Capital Tax Agreements are: France, India, Irish Republic, Italy, the Netherlands, Pakistan, South Africa, Sweden, Switzerland and the United States. As a result, Double Taxation Relief For Shipping provides tax practitioners with easy reference to all the pertinent provisions concerning international shipping operations which are contained in a particular tax agreement, unencumbered by extraneous provisions. Conse-