Category: Tuvalu

Business Brief – Double Tax Agreement – Residence – change of HMRC practice

Following an agreement between the UK and Jersey, HMRC has published an important change of interpretation on residence for treaty purposes. HMRC’s view now is that the better interpretation of residency article in the UK-Jersey Double Tax Agreement 1952 (“UK Jersey DTA”) is that it includes a tie breaker provision… – Continue reading

HMRC changes view on the company residence tie-breakers in certain double tax agreements

HMRC has reached an agreement with Jersey concerning the interpretation of the company residence tie-breaker in the Jersey-UK 1952 double tax agreement. This change also affects the interpretation of 15 other double tax agreements (DTAs) which have identical or very similarly worded company residence tie-breakers. The issue concerns dual residents… – Continue reading

Change in UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After reviewing other income tax treaties that contain similar provisions, HMRC will now take the view… – Continue reading

UK government amends view on DTA residence articles

UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs), reports Tax News. The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in… – Continue reading

UK Gov’t Amends View On DTA Residence Articles

UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs). The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in their 1952 DTA…. – Continue reading