UK Changes Interpretation of Residence Articles in 16 Tax Treaties
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 …
Continue Reading