269.This section is a machinery provision for resolving disputes under DTAs. It is based on section 815AA(1) to (3) of ICTA, section 277(1) of TCGA and section 194(1) of FA 1993.
270.Subsection (4) extends the scope of the section to include the enactments relating to capital gains tax and the enactments relating to PRT. This brings the law into line with practice. See Change 8 in Annex 1. The same change is made in section 125.