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UK-Chile Tax Treaty MFN Clause Triggered for Interest and Royalties

07 March 2018

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Treaty Development

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United Kingdom-Chile

UK HMRC has issued an update that the MFN clause in the 2003 UK-Chile tax treaty was triggered following the entry into force of the 2016 Chile-Japan tax treaty. As a result, the following withholding tax rates apply under the UK-Chile tax treaty in respect of interest income from 1 January 2017: The rate is 4% where: The interest is derived from loans granted by banks and insurance companies (5% if part of an arrangement involving back-to-back loans or similar arrangements); The interest is derived from a sale on credit paid by the purchaser of machinery and equipment to a...