The CIOT has responded to HMRC’s review of the priorities for the UK’s network of double taxation agreements for 2022/23.
The CIOT welcomes confirmation that, following Brexit, HMRC will continue to prioritise renegotiation of European double taxation treaties (DTTs) to try to replicate the benefits of the interest and royalty and parent and subsidiary directives. It also reiterates its position that UK companies would benefit from a new addition to article 13 of the OECD model for treaties with EU/EEA members that would extend the merger directive bilaterally. The CIOT’s view is that the DTTs with Germany and Italy are the most important to seek to renegotiate, due to the size of their economies.
The CIOT also notes:
The CIOT has responded to HMRC’s review of the priorities for the UK’s network of double taxation agreements for 2022/23.
The CIOT welcomes confirmation that, following Brexit, HMRC will continue to prioritise renegotiation of European double taxation treaties (DTTs) to try to replicate the benefits of the interest and royalty and parent and subsidiary directives. It also reiterates its position that UK companies would benefit from a new addition to article 13 of the OECD model for treaties with EU/EEA members that would extend the merger directive bilaterally. The CIOT’s view is that the DTTs with Germany and Italy are the most important to seek to renegotiate, due to the size of their economies.
The CIOT also notes: