U.S. IRS Formally Announces Competent Authority Arrangements with the UK Regarding Application of 2001 Tax Treaty
The U.S. IRS has formally announced two competent authority arrangements with the UK in Internal Revenue Bulletin: 2021-33, issued 16 August 2021. As previously reported, the arrangements concern the application of the "derivative benefits test" in paragraph 3 of Article 23 (Limitation on benefits) of the 2001 US-UK Tax Treaty and the interpretation of the term "North American Free Trade Agree…
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