New Double Taxation Treaties published
Over the last month, HMRC have been publishing the updated 2008 versions of the various Double Taxation Treaties, as agreed with the Organisation for Economic Co-operation and Development (OECD).
There are no major technical changes to the treaties. The Statutory Instruments issued so far are listed below, and contain a useful reminder summary of their rights for taxpayers with international affairs:
Double Taxation Conventions aim to eliminate the double taxation of income or gains arising in one country and paid to residents of another country. They do this by dividing the taxing rights that each treaty partner has under its domestic law over the same income and gains. They provide additional protection for taxpayers by specific measures combating discrimination in tax treatment. More generally, Conventions benefit the taxpayer by ensuring certainty of treatment and, as far as possible, by reducing compliance burdens. Conventions also serve an Exchequer protection role by including provisions to combat avoidance and evasion — not least by measures providing for the exchange of information between revenue authorities. They also encourage and maintain international consensus on the appropriate tax treatment of cross-border economic activity and thus promote international trade and investment.