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UK Changes Interpretation of Residence Articles in 16 Tax Treaties

|Treaty Development|United Kingdom-Antigua-Belize-Brunei-Mya ...
United Kingdom-Antigua-Belize-Brunei-Myanmar-Greece-Grenada-Guernsey-Isle Of Man-Jersey-Kiribati-Malawi-Montserrat-Saint Kitts and Nevi-Sierra Leone-Solomon Isl-Tuvalu

On 30 November 2015, the UK HMRC issued a policy paper announcing a change in interpretation of the residence articles in tax treaties with 16 jurisdictions. The interpretation is that the articles include a tie-breaker clause to decide where a company is to be treated as resident for the purposes of the treaties. Under this interpretation, a dual-resident company will be treated as a resident …

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