UK–US treaty agreement on dual consolidated losses

The UK's Her Majesty's Revenue and Customs (HMRC) and the US Internal Revenue Service (IRC) signed an agreement regarding dual consolidated losses on 6 October 2006 as competent authorities under the UK-US tax treaty. The UK–US tax treaty was signed on 24 July 2001 and entered into force on 31 March 2003.

Both the UK and US rules deny relief for losses that have been relieved in another territory (dual consolidated losses). Both states also deny relief that cou…