Tax treaties with Serbia and Slovenia updated for MLI

The government has published ‘synthesised’ texts of the UK’s double taxation conventions with Yugoslavia and Slovenia, as modified by the BEPS multilateral instrument (MLI), which the UK has concluded with Serbia and Slovenia.

The BEPS MLI allows jurisdictions to integrate elements of the OECD/G20 BEPS project into their existing bilateral tax treaties. In July, HMRC published the final list of UK reservations and notifications for the UK’s ‘covered tax agreements’ under the MLI.

The UK signed the MLI with Serbia and Slovenia respectively on 7 June 2017, the provisions of which came into force on 1 October 2018.

In relation to Serbia, the MLI modifies the 1981 UK/Yugoslavia double tax convention and is effective from:

• 1 January 2019 for taxes withheld at source;
• 1 April 2019 in the UK for corporation tax;
• 6 April 2019 in the UK for income tax and CGT; and
• 1 April 2019 for all other taxes levied by Republic of Serbia for taxable periods beginning on or after that date.

For Slovenia, the MLI modifies the 2007 UK/Slovenia double taxation convention with effect from:

• 1 January 2019 for taxes withheld at source on amounts paid or credited to non-residents;
• 1 April 2019 for corporation tax;
• 6 April 2019 for income tax and CGT; and
• 1 April 2019 for all other taxes levied by Slovenia for the taxable period beginning on or after that date.

See the synthesised text of the MLI and 1981 UK/Yugoslavia DTC (https://bit.ly/2RUecKX); and synthesised text of the MLI and 2007 UK/Slovenia DTC (https://bit.ly/2yILFPZ).