HMRC has revised its interpretation of the residence articles in 16 double taxation agreements, taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously, HMRC regarded dual-resident companies as outside the scope of the treaties.
Profits from US LLCs and double tax relief
Tony Beare (Slaughter and May) examines the recent eagerly anticipated First-tier Tribunal decision of Next Brand Ltd v HMRC on dividend boosters.
Online retailer Amazon has confirmed that, from 1 May, it is now recording retail sales made to customers in the UK through the UK branch. Previously such sales were recorded in Luxembourg.
HMRC has been quick to publicise its success in a tax case involving Next Brand Ltd, which is part of the Next group, over its use of a tax avoidance structure known as a rate-booster.
New regulations (The Bank Levy (Double Taxation Arrangements) (Netherlands) Regulations, SI 2015/344) will come into force on 17 March 2015 to provide for double taxation relief in respect of the Netherlands bank tax paid by groups or entities for which the Netherlands is the home state, against
HMRC has announced that a first-time comprehensive double taxation convention between the UK and Algeria was signed in Algiers on 18 February 2015 by Philip Hammond MP, secretary of state for foreign and Commonwealth affairs, and Ramtane Lamamra, minister of foreign affairs of Algeria.
Allan Cinnamon provides an update on tax treaty developments
In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.