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DOUBLE TAX RELIEF


The government has abandoned a consultation – due to close in less than a fortnight – on proposed measures to counter tax avoidance ‘exploiting’ double tax treaties.

A new comprehensive double taxation convention between the UK and Hungary was signed yesterday and will enter into force when both countries have completed their legislative procedures.

HMRC are to  publish an update to last month’s ‘tax treaties anti-avoidance’ consultation in the light of concerns raised by business and tax advisers.

The proposals would affect a number of entirely bona fide commercial arrangements, argues Philip Baker QC. Kevin Cummings considers whether the proposals amount to an unecessary own goal. HMRC also give their response (below)

A protocol to the UK/Qatar double taxation agreement entered into force on 27 July. The text of the protocol is set out in the schedule to The Double Taxation Relief (Qatar) Order, SI 2011/1684.

Interest payable to overseas investors in UK debt securities is subject to UK withholding tax. Ben Jones and Deepesh Upadhyay examine the four commonly used mitigating routes

HMRC are seeking views on draft legislation, earmarked for Finance Bill 2012, to counter tax avoidance schemes exploiting double taxation agreements.

The following orders bring into effect agreements for the exchange of information between the UK and Belize, Dominica, Grenada and San Marino respectively.

The Double Taxation Relief (Qatar) Order, SI 2011/1684, brings into effect arrangements set out in a protocol which amends an agreement (SI 2010/241) between the UK and the State of Qatar.

A first-time comprehensive double taxation convention between the UK and the Republic of Armenia was signed on 13 July, HMRC announced.

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