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 double tax...
For more information on the other types of exemptions and reliefs from UK withholding tax that are available, see Practice Note: Exemptions and reliefs from UK...
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 entered an...
The exchange of information between HMRC and tax authorities in other territories is an essential tool in enabling authorities both to administer and enforce their own...
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 individuals acquiring...
In October 2013, the Isle of Man, Jersey and Guernsey each signed inter-governmental agreements (IGAs) with the UK to implement the automatic exchange of tax information....
Article 10 of the OECD model convention is concerned with the taxation of dividends paid cross border. In particular it deals with the allocation of taxing rights...
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 entered an...
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 entered an...
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 convention (DTT),...
The Liechtenstein Disclosure Facility (LDF) was a voluntary disclosure facility that extended to all main taxes including, but not limited to, income tax, corporation...
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 entered an...
Non-discrimination and Article 24 of the OECD model convention Non-discrimination is a term that is used generally to deal with preventing one person from being treated...
Since 2007, HMRC has offered a series of disclosure facilities to individuals with offshore investments. These facilities provide a limited opportunity for individuals to...
Double tax treaties or conventions (DTTs) have a dual nature. They are: • conventions between states (the contracting states), governed by international law, and • part...
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 (No 2) Act 2017...
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 entered an...
The three tables below set out the UK's double taxation treaties that relate to income and corporation taxes that: • are currently in force • have completed the UK...
The Organisation for Economic Cooperation and Development (OECD)’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit...
The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and obtain an expedited authorisation to pay UK source interest to a non-UK...
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 tax at the basic rate...
This Practice Note provides an introduction to the Organisation for Economic Co-operation and Development (OECD)’s Multilateral Convention on Mutual Administrative...
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 tax at the basic rate...
On 6 October 2011, the governments of Switzerland and the UK signed an agreement to co-operate on tax matters entitled the UK-Swiss Confederation Taxation Cooperation...
Double tax treaties (DTTs) allocate taxing rights between jurisdictions, with the primary aim of ensuring that taxpayers do not suffer tax on the same income twice in...