Responding to HMRC’s review of double tax treaty priorities for 2025/26 the CIOT has again called for renegotiation of agreements with EU member states to replicate the benefits lost when the UK left the EU – particularly in terms of the Interest and Royalty Parent and Subsidiary and Mergers Directives. The response includes the following key points:
The UK would benefit from stepping up its policy around seeking mandatory binding arbitration provisions in its treaties to enhance tax certainty particularly as the GloBE rules come into force around the world (although perhaps with some notable exceptions).
Post-Brexit the UK no longer benefits from protections around non-discriminatory tax treatment by Member States. The Institute suggests that the UK should now reconsider its position in relation to Article 24(6) of the OECD Model Double Tax Convention – which where adopted provides...
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Responding to HMRC’s review of double tax treaty priorities for 2025/26 the CIOT has again called for renegotiation of agreements with EU member states to replicate the benefits lost when the UK left the EU – particularly in terms of the Interest and Royalty Parent and Subsidiary and Mergers Directives. The response includes the following key points:
The UK would benefit from stepping up its policy around seeking mandatory binding arbitration provisions in its treaties to enhance tax certainty particularly as the GloBE rules come into force around the world (although perhaps with some notable exceptions).
Post-Brexit the UK no longer benefits from protections around non-discriminatory tax treatment by Member States. The Institute suggests that the UK should now reconsider its position in relation to Article 24(6) of the OECD Model Double Tax Convention – which where adopted provides...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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