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Primarolo Unveils Plans For New DTAs

by Jason Gorringe, Tax-News.com, London

28 July 2006


The UK's Paymaster General, Dawn Primarolo this week announced details of the UK's treaty negotiating priorities for the year to 31 March 2007.

She observed that:

"I am pleased to announce the programme of work on double taxation agreements for the year to 31 March 2007. Bilateral double taxation agreements play an important role in facilitating trade investment and helping businesses to deal with tax systems across borders."

The Government reviews the UK's DTA priorities each year to ensure that the treaty network continues to meet the needs of the businesses and individuals receiving income from abroad.

HM Revenue & Customs monitors the DTA networks of other countries and invites representations from business, individuals, representative bodies, other government departments and others with an interest in this area.

According to the HMRC programme to 31 March 2007, the department plans to complete work on new DTAs with Macedonia, Moldova, Poland, Slovenia and Thailand; and on a Protocol with Switzerland.

It also revealed that it intends to progress negotiations with the Cayman Islands, China, Germany, Hungary, Faroe Islands and Saudi Arabia; and also to progress negotiations with the Crown Dependencies and Overseas Territories on Tax Information Exchange Agreements (TIEAs).

Plans are additionally in the pipeline for Protocols to amend the existing DTAs with Australia, Mexico, New Zealand and South Africa.

Recent developments unveiled by HMRC included the fact that the DTA with Georgia, signed in London on 13 July 2004, entered into force on 11 October 2005. The provisions of the DTA applied in the UK from 1 April 2006 (for corporation tax) and from 6 April 2006 (for income tax and capital gains tax). The provisions of the DTA applied in Georgia from 1 January 2006.

New DTAs with Botswana and Japan were approved by Parliament on 17 May 2006.

Agreements on the taxation of savings with Guernsey, Jersey, the Isle of Man, Anguilla, the British Virgin Islands, the Cayman Islands, Montserrat, the Turks & Caicos Islands, the Netherlands Antilles and Aruba all came into effect on 1 July 2005, and a similar Agreement with Gibraltar was approved by Parliament in the spring and entered into force on 1 April 2006.

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