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UK/US Tax Treaty

Mark Schofield Tax Partner and Eric Peden Tax Senior Manager both of PricewaterhouseCoopers LLP in London discuss limitation on benefits and treaty qualification rules under the UK/US tax treaty
It has now been more than three years since the new UK-US treaty entered into force for withholding taxes on 1 May 2003 representing the first US treaty to provide for 0% dividend withholding for distributions to corporate shareholders in certain circumstances. This approach has now been followed in other US treaties.
For UK investors the 0% US dividend withholding rate came with a price. New treaty provisions included a comprehensive 'Limitation on Benefits' article that was generally consistent with standard US treaty policy but which represented a unique set of anti-treaty-shopping rules from a UK treaty...

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