September 17, 2021 by eklose
6. The period referred to in paragraph 5 of this Article may be extended by mutual agreement between the States Parties. 2. This Convention shall also apply to all taxes which are identical or substantially similar levied by a Contracting State or by one of its political subdivisions after the date of signature of this Convention, in addition to or instead of the taxes of the Contracting State referred to in paragraph 1 of this Article. The competent authorities of the States Parties shall inform each other of any substantial changes to their respective tax legislation. 5. The term “interest” used in this Article means income from claims of any kind, whether or not secured by a mortgage and whether or not they are entitled to participate in the profits of the debtor, in particular income from government securities and income from bonds or bonds, including over-invoicing and haircuts related to such securities, as well as all obligations related to these securities. Including income, which is treated as borrowed income under the tax legislation of the State Party where the income is received. Default interest shall not be considered as interest within the meaning of this Article. If a person is not considered to be resident in the United Kingdom, the person would only be taxable in the United Kingdom under the current double taxation convention if the income comes from UK activities. This is important because it means that all income and profits of non-UK capital are protected against UK taxes.
A comprehensive convention (SI 1994/3212) has effects Each double taxation convention is different, although many very similar directives follow, even if the details are different. Determining the position of the person`s “contractual residence” is essential to determine whether it is possible to do so and how to apply a double taxation treaty, given that this is the country of contractual residence that generally assumes the taxing rights. There are also measures to protect nationals and businesses of one country from discriminatory taxes in the other country (Article 25), to consult to resolve difficulties in the application or interpretation of the agreement (Article 26), to exchange information between the tax authorities of the two countries (Article 27) and to treat diplomatic or consular officials (Article 28). That`s why we offer a free initial consultation with a qualified accountant who can provide you with answers to your questions and help you understand if a double taxation treaty might apply to you and help you save significant amounts of unnecessary taxes. The table below lists the countries that have concluded a double taxation treaty with the United Kingdom (as of 23 October 2018). An up-to-date list of active and historical double taxation treaties can be found on the UK Government`s website. On 18 A Protocol (SI 2010/2686) amending the 1994 Agreement entered into force on 1 January 2011. It amended the provisions on dividends and exchange of information and introduced an additional article on recovery assistance. Since there are many rules and complications that can arise when applying double taxation treaties, it is important to seek the help of a qualified and experienced accountant. 2. Paragraph 1 shall not affect the taxation of the company in respect of the profits from which dividends are paid. .