Double taxation conventions - Agreement between the UK and Japan signed on 2 February

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A comprehensive Double Taxation Convention between the United Kingdom and Japan was signed in London on 2 February 2006. The new Convention will replace the existing Convention that dates from 10 February 1969 (as amended on 14 February 1980).

Important features of the new treaty include complete elimination of source-country withholding taxes on: all royalty income; certain interest income, including interest income earned by financial institutions; and dividend income paid to parent companies with a controlling interest in the paying company.

The Convention will enter into force once both countries have completed their constitutional procedures. In the United Kingdom the provisions of the Convention will take effect from 1st January with respect to taxes withheld at source; 1 April (for corporation tax purposes), and from 6 April (for income tax and capital gains tax purposes) following the date of entry into force. In Japan, the provisions will take effect (in respect of taxes withheld at source and taxes chargeable) from 1 January following the date of entry into force.

Further information:
Double Taxation Convention: Japan
UK/Japan Double Taxation Convention and Protocol

Protocol to the Agreement between the UK and Switzerland

A protocol amending the 1977 UK-Switzerland double taxation convention has been agreed at official level. The main amendments are the elimination of taxation at source on dividends where the beneficial owner of the dividends has a substantial participation in the payer or is a pension scheme. The protocol also amends the exchange of information article. It provides that, in future, information will be exchanged in cases of tax fraud or the like, and in cases involving holding companies.

The protocol also contains measures relating to pensions. In future, lump sum payments may be taxed only by the state in which they arise. Also, pension contributions paid to a scheme recognised for tax purposes in one country may, under certain conditions, be deductible in the other country.

Further information:
UK-Switzerland Double Taxation Convention

...back to 9 February 2006


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International - Double Taxation Agreements

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United Kingdom and Georgia

HMRC has announced the entry into force, on 11 October 2005, of the Double Taxation Agreement with Georgia. The Agreement was signed in London on 13 July 2004 and entered into force on 11 October 2005. In the United Kingdom, the provisions of the Agreement will take effect from 1 April 2006 (for corporation tax purposes), and from 6 April 2006 (for income tax and capital gains tax purposes). In Georgia, the provisions will take effect from 1 January 2006.

United Kingdom and the Republic of Moldova

HMRC has announced forthcoming discussions about a new Double Taxation Agreement with the Republic of Moldova. Representations are invited from interested parties.

...back to 20 October 2005


Source:
Double Taxation Agreements: Georgia and Moldova
The Double Taxation Relief (Taxes on Income) (Georgia) Order 2004
Explanatory Memorandum to the Draft Double Taxation Relief (Taxes on Income) (Georgia) Order 2004


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