DOUBLE TAX RELIEF

A new comprehensive double taxation agreement between the UK and the People’s Republic of China was signed on 27 June.

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

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...

The Court of Appeal took a purposive approach to interpreting the UK/US double tax treaty in Bayfine UK. Ed Denny and Adam Willman consider the implications of the decision

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.

The following statutory instruments bring into effect arrangements for the exchange of information for tax purposes between the governments of the UK and Antigua and Barbuda, Saint Lucia, Saint Christopher (Saint Kitts) and Nevis, and Saint Vincent and the Grenadines respectively.

The UK/Turks and Caicos Islands tax information exchange arrangement entered into force on 25 January 2011, HMRC announced.