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Full treaty territory status changes

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HMRC has updated its list of double tax treaties that it regards as containing an appropriate non-discrimination article. The non-inclusion of various territories with new treaties (such as Jersey) is notable, as is the removal from the list of several territories (including Hong Kong). HMRC has taken this position on the basis that such territories are not ‘states’. Groups with entities in these jurisdictions need to consider any applicable tax implications, especially where reliance has been placed on a territory’s previous inclusion in HMRC’s list.

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