HMRC has added the UK/USA Competent
Authority Agreement (CAA) signed in July 2021 to its international treaty
collection. The agreement provides that UK residents can continue to be
considered as ‘a resident of a member state of the European Community’ for the
purposes of applying the ‘derivative benefits test’ in para 3 of article
23 of the UK/US double taxation convention. In essence, article 23 sets out
that residents of contracting states are entitled to the benefits of the
convention subject to various limitations and conditions. A second CAA has also
been published which updates references to the North American Free Trade
Agreement (NAFTA) in the UK/USA convention. NAFTA has been superseded by the
Agreement between the USA, Mexico and Canada (USMCA)
and references have been updated accordingly.
HMRC has added the UK/USA Competent
Authority Agreement (CAA) signed in July 2021 to its international treaty
collection. The agreement provides that UK residents can continue to be
considered as ‘a resident of a member state of the European Community’ for the
purposes of applying the ‘derivative benefits test’ in para 3 of article
23 of the UK/US double taxation convention. In essence, article 23 sets out
that residents of contracting states are entitled to the benefits of the
convention subject to various limitations and conditions. A second CAA has also
been published which updates references to the North American Free Trade
Agreement (NAFTA) in the UK/USA convention. NAFTA has been superseded by the
Agreement between the USA, Mexico and Canada (USMCA)
and references have been updated accordingly.
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