Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published, writes Mark Saunders (PwC).
On 17 January, the governments of the UK and Israel signed a protocol amending their 1962 double taxation convention.
The UK’s new double taxation agreements and protocol with Guernsey, signed in July 2018, entered into force on 7 January 2019.
The agreement and protocol take effect from:
The Sanctions and Anti-Money Laundering Bill 2018 requires the government to legislate by 31 December 2020 for the British Overseas Territories to establish public registers of company beneficial ownership.
Belize has become the 86th country to sign the OECD’s ‘Multilateral convention to implement tax treaty related measures to prevent BEPS’. Monaco has deposited its instrument of ratification with the OECD and the convention will come into effect for that country on 1 May 2019.
The governments of the UK and Cyprus have signed a protocol to their 2018 double taxation convention, allowing individuals who were in receipt of government service pensions at the time the 2018 convention came into force to elect for the provisions of the 1974 convention to continue to apply to
The UK’s new double taxation agreements and Protocols with the Isle of Man and Jersey, signed in July 2018, entered into force on 19 December 2018. The new agreement and Protocol with Guernsey has not yet entered into force.