Orbitax Tax News & Alerts
United Kingdom's Tax news & updates from Orbitax and partners
United Kingdom Tax News
Court of Appeals of Paris decides on concept of beneficial owner under France-UK tax treaty
The Inland Revenue announced on 12 July 2005 details of the United Kingdom's tax treaty negotiating priorities for the year to 31 March 2006. These include:
The Internal Revenue Service (IRS) has released the text of a private letter ruling (PLR) on 3 June 2005 holding that stock of a US corporation owned by a UK company through foreign entities that elect to be treated as disregarded entities under the US check-the-box regulations can qualify for the zero dividend withholding rate under
Following a final round of negotiations on 26 May 2005, the United Kingdom and Japan reached an agreement in principle on a new tax treaty. Once in force, the new treaty will replace the United Kingdom-Japan income tax treaty of 10 February 1969 (as amended by the 1980 protocol). Further details of the new treaty are not yet available.
Entry into force on 21 December 2004, effective as from 1 January 2005 in Chile and as from 1 April 2005 (in respect of corporation tax, for any financial year beginning on or after 1st April) or 6 April 2005 (in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6th April 2005) in the United Kingdom.
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