The ‘equivalent beneficiary’ article of foreign tax treaties may require certain groups to restructure to prepare for life after 31 Dec 2020

In view of the imminent Brexit deadline of 31 December 2020, it may be worth reviewing the ability of groups to access the benefits of foreign tax treaties through the ‘equivalent beneficiary’ provisions.  An equivalent beneficiary will include a member...

2019 Protocol to UK/Israel Double Tax Convention comes into force

The 2019 protocol amending the 1977 UK/Israel DTA entered into force on 28 October, although it takes effect: In both countries:  For taxes withheld at source for amounts paid or credited on or after 1 January 2020 In Israel: For Income...

New UK/Austria tax treaty is signed

A new double tax agreement between the UK and Austria was signed on 23 October 2018. Subject to both countries having completed their parliamentary procedures and exchanged diplomatic notes, it will to come into force for the fiscal year beginning...

Double tax treaty could not prevent transfer of asset abroad provisions from applying

In the case of Davies and others v HMRC [2018] UKFTT 0559 (TC), the First Tier Tax Tribunal (FTT) has held that the appellants were subject to tax as a result of the transfer of assets abroad rules at s720...

Certificates of residence for tax purposes – for companies

A foreign tax authority may require a company to obtain certification from HMRC that the company is UK resident in order to obtain relief from certain taxes. There may also be a requirement for HMRC to certify that other conditions...

Withholding tax on interest – does the “Tinkerman” strike?

Claudio Ranieri (the ex-Leicester City FC manager, for those who have never heard of him) has often been referred to as the “Tinkerman” because of the changes he would constantly make to some of the football teams he managed.  Will...

HMRC changes view on the company residence tie-breakers in certain double tax agreements

HMRC has reached an agreement with Jersey concerning the interpretation of the company residence tie-breaker in the Jersey-UK 1952 double tax agreement.  This change also affects the interpretation of 15 other double tax agreements (DTAs) which have identical or very...

International Tax Guest Lecture

Today, Mazars was very pleased to welcome Dr Tom O’Shea and his LL.M in International Tax Law students from the Centre for Commercial Law Studies, Queen Mary, University of London. Dr Tom O’Shea delivered a very interesting guest lecture entitled...