In its response to HMRC’s review of priorities for the UK’s double tax treaties for 2024/25, the CIOT have called for HMRC to continue to prioritise renegotiation of the European double tax agreements that were lost when the UK left the EU, particularly to replicate the benefits of the Interest and Royalty, Parent-Subsidiary and Mergers Directives. It also believes that several other DTAs could be made more competitive for the UK, particularly in light of the Netherlands having negotiating a 0% withholding tax rate on royalties with Singapore, but the UK/Singapore DTA provides a rate of 8%.
an update on whether there will be negotiations on treaty taxing rights associated with income flowing from remote and hybrid working with increased working across borders following the Covid-19 pandemic;
whether binding arbitration provisions need to be negotiated for the UK’s treaties to support dispute resolution in anticipation of the implementation of Pillar Two across the world (in line with BEPS Action 14); and
guidance on the principal purpose test and anti-fragmentation provisions, as applied to various tax agreements by the BEPS multilateral instrument (see articles 7 and 13 of the MLI).
In its response to HMRC’s review of priorities for the UK’s double tax treaties for 2024/25, the CIOT have called for HMRC to continue to prioritise renegotiation of the European double tax agreements that were lost when the UK left the EU, particularly to replicate the benefits of the Interest and Royalty, Parent-Subsidiary and Mergers Directives. It also believes that several other DTAs could be made more competitive for the UK, particularly in light of the Netherlands having negotiating a 0% withholding tax rate on royalties with Singapore, but the UK/Singapore DTA provides a rate of 8%.
an update on whether there will be negotiations on treaty taxing rights associated with income flowing from remote and hybrid working with increased working across borders following the Covid-19 pandemic;
whether binding arbitration provisions need to be negotiated for the UK’s treaties to support dispute resolution in anticipation of the implementation of Pillar Two across the world (in line with BEPS Action 14); and
guidance on the principal purpose test and anti-fragmentation provisions, as applied to various tax agreements by the BEPS multilateral instrument (see articles 7 and 13 of the MLI).
