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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 of the jurisdiction in which it is managed and controlled for the purpose of the treaty. If managed and controlled in both the UK and the other jurisdiction, it will remain outside the scope of the treaty.

The change in interpretation affects the UK's tax treaties with the following jurisdictions:

  • Antigua;
  • Belize;
  • Brunei;
  • Burma (Myanmar);
  • Greece;
  • Grenada;
  • Guernsey;
  • Isle of Man;
  • Jersey;
  • Kiribati;
  • Malawi;
  • Montserrat;
  • St Kitts & Nevis;
  • Sierra Leone;
  • Solomon Islands; and
  • Tuvalu

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