CROSS BORDER

Michael McKenna and Kunal Vyas review the impact of Bayfine UK and the OECD discussion draft on the meaning of ‘beneficial ownership’ on the interpretation of double tax treaties

The OECD has urged all countries to sign up to a revised international convention designed to help counter cross-border tax evasion.

A comprehensive double taxation convention between the UK and the Federal Democratic Republic of Ethiopia was signed on 9 June.

TIEAs signed in January 2010 between the UK and the following territories entered into force on 19 May:

The OECD Committee on Fiscal Affairs has invited public comments on draft changes to the commentary on the OECD Model Tax Convention concerning the meaning of the term ‘beneficial owner’. The term has given rise to different interpretations by...

Canada’s framework for the maintenance of ownership information is in place but ‘requires improvement’ in relation to nominees and bearer shares, according to the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes.

The International Mutual Administrative Assistance in Tax Matters Order, SI 2011/1079, brings into effect arrangements set out in a Protocol (signed on behalf of the UK in May 2010) to the joint Council of Europe/OECD Convention on Mutual Administrative Assistance in Tax Matters.

The Double Taxation Relief and International Tax Enforcement (Montserrat) Order, SI 2011/1083, brings into effect an arrangement between the governments of the UK and Montserrat which amends an existing arrangement for the avoidance of double taxation and the prevention of fiscal evasion.