Double tax treaties

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Practice notes
Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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19th May
Practice notes
Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes
How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May

Most recent Double tax treaties content

Practice notes
Automatic exchange of information—outlineSTOP PRESS: The government has enacted amending regulations that significantly restrict the scope of the UK’s...
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1st Jul
Practice notes
Royalties articles in double tax treatiesArticle 12 of the OECD model tax convention (OECD model convention) is concerned with the taxation of...
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Produced in partnership with David Klass of Hunton Andrews Kurth 21st Jun
Practice notes
Principles of interpretation of double tax treatiesDouble tax treaties or conventions (DTTs) have a dual nature. They are:•conventions between states...
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Produced in partnership with David Klass of Hunton Andrews Kurth 21st Jun
Practice notes
Interest articles in double tax treatiesArticle 11 of the OECD model convention is concerned with the taxation of interest paid cross border. In...
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Produced in partnership with David Klass of Hunton Andrews Kurth 21st Jun
Practice notes
Dividend articles in double tax treatiesArticle 10 of the OECD model convention is concerned with the taxation of dividends paid cross border. In...
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Produced in partnership with David Klass of Hunton Andrews Kurth 16th Jun
Practice notes
Non-discrimination in double tax treatiesNon-discrimination and Article 24 of the OECD model conventionNon-discrimination is a term that is used...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th Jun
Q&As
What are the UK’s automatic exchange of information obligations with Guernsey?What are the UK’s automatic exchange of information obligations with...
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6th Jun
Q&As
Can a double tax treaty relief claim be made for withholding tax paid to HMRC in the form of a funding bond?Unless an exemption or relief applies,...
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6th Jun
Practice notes
Offshore disclosure facilities—outlineSince 2007, HMRC has offered a series of disclosure facilities to individuals with offshore investments. These...
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5th Jun
Practice notes
The syndicated loan scheme (SLS)Unless an exemption or a relief applies, a payment of yearly interest arising in the UK (ie with a UK source) is...
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5th Jun
Practice notes
Key definitions and concepts relating to double tax treatiesThis Practice Note explains some of the key definitions and concepts a tax lawyer will...
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Produced in partnership with David Klass of Hunton Andrews Kurth 5th Jun
Practice notes
Anti-avoidance and double tax treatiesWhat are the anti-avoidance concerns in a double tax treaty context?As discussed in Practice Note: What are...
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Produced in partnership with David Klass of Hunton Andrews Kurth 5th Jun
Practice notes
What are double tax treaties?Double tax treaties (DTTs) allocate taxing rights between jurisdictions, with the primary aim of ensuring that taxpayers...
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Produced in partnership with David Klass of Hunton Andrews Kurth 5th Jun
Practice notes
Claiming relief under a double tax treaty in relation to income or gains from UK real estateMany investors in UK property are based outside the UK....
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Produced in partnership with Charles Goddard of Rosetta Tax 5th Jun
Practice notes
Assistance in collection in tax mattersIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period...
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Produced in partnership with David Klass of Hunton Andrews Kurth 5th Jun
Practice notes
The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...
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5th Jun
Practice notes
The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM)This Practice Note provides an introduction to the...
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5th Jun
Practice notes
Liechtenstein Disclosure Facility [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.The Liechtenstein Disclosure Facility...
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5th Jun
Practice notes
The BEPS Multilateral InstrumentThe Organisation for Economic Cooperation and Development (OECD)’s Multilateral Convention to Implement Tax Treaty...
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5th Jun

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