Graham Samuel-Gibbon and Will Egan (Taylor Wessing) consider HMRC's updated list of double tax treaties and the tax implications for groups with entities in those jurisdictions.
Article 24 of the OECD Model Tax Convention provides that nationals of a contracting state to a double taxation treaty (DTT) should not be subject in the counterparty contracting state to any tax which is more burdensome than that to which nationals of the first contracting state in the same circumstances are subject. This is the ‘non-discrimination article’ of the convention which the UK has generally adopted with its respective DTT counterparties.
Over time various UK tax laws governing arrangements between entities resident in the UK and entities resident in other territories have differentiated between those territories that have a DTT with the UK containing an appropriate ‘non-discrimination article’ and those that do not....
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Graham Samuel-Gibbon and Will Egan (Taylor Wessing) consider HMRC's updated list of double tax treaties and the tax implications for groups with entities in those jurisdictions.
Article 24 of the OECD Model Tax Convention provides that nationals of a contracting state to a double taxation treaty (DTT) should not be subject in the counterparty contracting state to any tax which is more burdensome than that to which nationals of the first contracting state in the same circumstances are subject. This is the ‘non-discrimination article’ of the convention which the UK has generally adopted with its respective DTT counterparties.
Over time various UK tax laws governing arrangements between entities resident in the UK and entities resident in other territories have differentiated between those territories that have a DTT with the UK containing an appropriate ‘non-discrimination article’ and those that do not....
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:
