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United Kingdom Tax News

Treaty between United Kingdom and Japan signed

16 March 2006
UK

16 March 2006
UKCourt of Appeal decides on residence status of foreign company re inter alia Netherlands-UK treaty

16 March 2006
Protocol and MoU to treaty between Switzerland and UK initialled

16 March 2006
US Court

19 February 2006
The Chilean Tax Authorities has issued Circular Letter 63 of 24 November 2005. The Circular provides that, after consultation with the UK tax authorities, the term "United Kingdom", as used in Art. 3 Para. 1(c) of the tax treaty between Chile and the United Kingdom, does not include the "Overseas Territories" and the "Crown Dependencies".

1 January 2006
Pre-Budget Report for 2006-07

1 January 2006
Court of Appeals of Paris decides on concept of beneficial owner under France-UK tax treaty

21 September 2005
The Finance (No. 3) Bill was published on 26 May 2005. The Bill reintroduces into Parliament the provisions of the original Finance Bill 2005 that were dropped when the Finance Act 2005 was enacted. Important details include:

21 September 2005
The Internal Revenue Service (IRS) has released the text of a private letter ruling (PLR) on 3 June 2005 holding that stock of a US corporation owned by a UK company through foreign entities that elect to be treated as disregarded entities under the US check-the-box regulations can qualify for the zero dividend withholding rate under

3 August 2005
Following a final round of negotiations on 26 May 2005, the United Kingdom and Japan reached an agreement in principle on a new tax treaty. Once in force, the new treaty will replace the United Kingdom-Japan income tax treaty of 10 February 1969 (as amended by the 1980 protocol). Further details of the new treaty are not yet available.

3 August 2005
The Inland Revenue announced on 12 July 2005 details of the United Kingdom's tax treaty negotiating priorities for the year to 31 March 2006. These include:

3 August 2005
Entry into force on 21 December 2004, effective as from 1 January 2005 in Chile and as from 1 April 2005 (in respect of corporation tax, for any financial year beginning on or after 1st April) or 6 April 2005 (in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6th April 2005) in the United Kingdom.

19 January 2005
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