BACKGROUNDDual Consolidated Loss Competent Authority Agreement • October 19th, 2006
Paragraph 3 of Article 26 of the Convention Between the Government of the United States of America and the Government of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains signed at London on July 24, 2001, and subsequently amended by a protocol signed July 19, 2002 (“Treaty”) allows the competent authorities of the Contracting States to consult together for the elimination of double taxation in cases not provided for in the Treaty.
