Double tax treaties

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Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Double tax treaties content

Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th Apr
Practice notes
What are the anti-avoidance concerns in a double tax treaty context?As discussed in Practice Note: What are double tax treaties?, one of the aims of...
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Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and obtain an expedited authorisation to pay UK source...
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9th Apr
Practice notes
Double tax treaties (DTTs) allocate taxing rights between jurisdictions, with the primary aim of ensuring that taxpayers do not suffer tax on the same...
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Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
For more information on the other types of exemptions and reliefs from UK withholding tax that are available, see Practice Note: Exemptions and...
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9th Apr
Practice notes
Unless an exemption or a relief applies, a payment of yearly interest arising in the UK (ie with a UK source) is generally subject to UK withholding...
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9th Apr
Practice notes
This Practice Note explains some of the key definitions and concepts a tax lawyer will come across when dealing with a double tax treaty or double tax...
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Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
Read More >
Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
Double tax treaties or conventions (DTTs) have a dual nature. They are:•conventions between states (the contracting states), governed by international...
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Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
Read More >
Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
The Organisation for Economic Cooperation and Development (OECD)’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base...
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9th Apr
Practice notes
Many investors in UK property are based outside the UK. The UK real estate sector is attractive to a range of investors, from high net worth...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.On 6 October 2011, the governments of Switzerland and the UK signed an agreement...
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9th Apr
Practice notes
What is the requirement to correct?The legislation for the requirement to correct (RTC) regime is set out in section 67 and Schedule 18 to the Finance...
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9th Apr
Practice notes
STOP PRESS: The government has enacted amending regulations that significantly restrict the scope of the UK’s disclosable arrangements rules (which...
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9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.In October 2013, the Isle of Man, Jersey and Guernsey each signed...
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9th Apr
Practice notes
This Practice Note provides an introduction to the Organisation for Economic Co-operation and Development (OECD)’s Multilateral Convention on Mutual...
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9th Apr
Practice notes
Since 2007, HMRC has offered a series of disclosure facilities to individuals with offshore investments. These facilities provide a limited...
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9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The Liechtenstein Disclosure Facility (LDF) was a voluntary disclosure facility...
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9th Apr

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