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Double taxation and information exchange: treaties now into force

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A double taxation convention between the UK and Germany, signed in March 2010, entered into force on 30 December 2010 (see SI 2010/2975). In the UK the provisions will take effect from 1 January 2011 for taxes withheld at source, from 1 April 2011 for corporation tax and from 6 April 2011 for income tax and capital gains tax purposes. In Germany the provisions will take effect from 1 January 2011.

A tax information exchange agreement between the UK and the Bahamas, signed in October 2009, entered into force on 7 January 2011 (see SI 2010/2684). The agreement will take effect in respect of criminal tax matters from 1 January 2004, and for all other matters for taxable periods commencing, or charges to tax arising, on or after 7 January 2011.

The protocol to the UK / Malaysia double taxation agreement entered into force on 28 December 2010 (see SI 2010/2971) and will have effect for tax years beginning on or after 1 January 2011.

A protocol to the UK / Mauritius double taxation convention was signed in Port Louis on 10 January 2011, updating the exchange of information article ‘to bring it into line with current OECD standards’. The protocol will enter into force once both countries have completed their legislative procedures and notified each other through diplomatic channels. The provisions will take effect on the date of the later of these notifications. In the meantime a copy is available on the HMRC website.

A double taxation arrangement between the UK and the Cayman Islands entered into force on 20 December 2010 (see SI 2010/2973). The provisions will take effect in the UK and the Cayman Islands for any income tax year of assessment commencing on or after 6 April 2011.

A tax information exchange agreement with Gibraltar entered into force on 15 December 2010 (see SI 2010/2680). The provisions will take effect in the UK and Gibraltar (a) in respect of requests relating to criminal tax matters on the date of entry into force; and (b) for all other requests, in relation to taxable periods beginning on or after the date of entry into force or, where there is no taxable period, for all charges to tax arising on or after that date.

The UK / Netherlands double taxation convention, signed in September 2008, entered into force on 25 December 2010.

The protocol to the UK / Singapore double taxation agreement entered into force on 8 January 2011.

The UK / Hong Kong double taxation agreement, signed in June 2010, entered into force on 20 December 2010.

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