Following the UK’s ratification and deposit of the BEPS multilateral instrument (MLI) on 29 June, HMRC has published the final list of UK reservations and notifications. The list contains all ‘covered tax agreements’ notified and details of agreements where the UK has opted not to apply certain provisions of the MLI. This replaces the provisional list published in April.
The MLI will enter into force for the UK on 1 October 2018 and will begin to have effect in the UK for UK tax treaties from:
1 January 2019 for taxes withheld at source;
1 April 2019 for corporation tax; and
6 April 2019 for income tax and capital gains tax.
The government introduced legislation in Finance Act 2018 s 32 and the Double Taxation Relief (Base Erosion and Profit Shifting) Order, SI 2018/630, to implement the MLI fully into UK law.
Following the UK’s ratification and deposit of the BEPS multilateral instrument (MLI) on 29 June, HMRC has published the final list of UK reservations and notifications. The list contains all ‘covered tax agreements’ notified and details of agreements where the UK has opted not to apply certain provisions of the MLI. This replaces the provisional list published in April.
The MLI will enter into force for the UK on 1 October 2018 and will begin to have effect in the UK for UK tax treaties from:
1 January 2019 for taxes withheld at source;
1 April 2019 for corporation tax; and
6 April 2019 for income tax and capital gains tax.
The government introduced legislation in Finance Act 2018 s 32 and the Double Taxation Relief (Base Erosion and Profit Shifting) Order, SI 2018/630, to implement the MLI fully into UK law.
