Expert insight from advisers at Mayer Brown, Pinsent Masons and Clifford Chance.
The new UK/Uruguay double taxation convention, signed in February 2016, entered into force on 14 November 2016. The convention has effect:
The OECD is consulting until 22 April 2016 on a number of specific questions concerning how the new treaty provisions included in the report on Action 6 of the BEPS action plan might affect the treaty entitlement of non-collective investment vehicles (non-CIVs).
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.
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