OrbitaxNon-standard treaty tie-breaker rules for company residence – guidelines published
|Treaty Development|United Kingdom
On 14 January 2013, HM Revenue & Customs (HMRC) published new section INTM120085 of the International Manual on company residence, providing clarification on non-standard treaty tie-breaker rules.
According to certain double taxation agreements, e.g. Canada - United Kingdom Income Tax Treaty (1978), Netherlands - United Kingdom Income Tax Treaty (2008)&nb…
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