My understanding is that it will be passed into law by way of order in council (a formality), but surely both countries are bound to honour the terms of what they signed up to in the interim?
Is it that the terms of the double taxation treaty are only relevant if an individual is resident (for tax purposes) in both the UK and the BVI? I don't understand from your analysis the basis upon which the 100 is not taxable in the UK in each of the scenarios (apologies for my ignorance, i'm not a financial sector worker).














