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UK Tax Treaties

UK Tax Treaties

Author: Alastair Munro
Publisher: Tolley
ISBN: 9781405755290
Published In: February 2013
Format: Paperback
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

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UK Tax Treaties considers the practical interpretation of the UK’s double tax treaties and domestic rules concerning relief from double taxation in the context of the taxation of income and gains in the UK of both UK residents and non-UK residents.

This title discusses the OECD model treaty and commentary and compares it with the UN Model and the UK’s double tax treaty network. It covers the main case law surrounding the interpretation of double tax treaties and the UK unilateral relief rules. There is also a chapter dealing with key EU treaty matters. Other topics dealt with include the UK domestic double tax relief rules relating to distributions, interest, royalties, capital gains and foreign permanent establishments.

UK Tax Treaties Highlights:
- Over 100 worked examples to aid understanding of key principles
- Coverage of important case law including recent precedents
- Focus on the latest OECD and UN model treaties
- Discussion of HMRC practice
- Written by Alastair Munro, International Corporate Tax Director, KPMG
1. Introduction
2. Historical background to double tax relief and treaties
3. UK domestic rules (income)
4. UK domestic rules (capital gains)
5. UK domestic rules (distributions)
6. UK domestic rules (non-residents)
7. Special companies (e.g., financial traders)
8. Background to treaties and OECD/UN models/commentary
9. Articles in agreements - scope and definitions (e.g. PE)
10. Articles in agreements business profits
11. Articles in agreements - associated enterprises
12. Articles in agreements shipping and air transport
13. Articles in agreements - dividends, interest and royalties
14. Management fees
15. Capital gains
16. Independent personal services
17. Dependent personal services
18. Directors' fees
19. Artists and athletes
20. Pensions and annuities
21. Government service
22. Professors, teachers, students and apprentices
23. Income not expressly mentioned/other income
24. Capital
25. Non-discrimination
26. Mutual agreement
27. Exchange of Information
28. Territorial extension
29. Entry into force/termination
30. Treaty shopping and other avoidance
31. EU Treaty matters
Appendices
By Alastair Munro, Director for International Corporate Tax at KPMG; with co-authors Teresa Nogueira and Jo Harrison, KPMG