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Double taxation conventions

Details of the coming year's programme of work on double taxation conventions has been announced.
The Government plans to complete work on new conventions with the Faroes, Macedonia, Moldova, Slovenia and Thailand; and on protocols with Australia, Mexico, New Zealand, South Africa and Switzerland. It also plans to complete new tax information exchange agreements (TIEAs) with Jersey, Guernsey, the Isle of Man, Anguilla, Bermuda and the British Virgin Islands.
Negotiations are to be progressed with Bahrain, the Cayman Islands, China, Croatia, Germany, Hungary, Luxembourg, Libya, Netherlands, Peru and Saudi Arabia. New talks are to be commenced with the Turks & Caicos Islands, the Netherlands Antilles, Aruba, the Bahamas and Panama on TIEAs. Recent conventions have come into force with the following countries:

• Republic of Botswana — the provisions have effect from 1 April 2007 (for corporation tax purposes), and from 6 April 2007 (for income tax and capital gains tax purposes). In Botswana, the provisions take effect from 1 July 2007.
• Japan — the provisions take effect from 1 January 2007 (for taxes withheld at source), 1 April 2007 (for corporation tax purposes), and from 6 April 2007 (for income tax and capital gains tax purposes). In Japan, the provisions take effect from 1 January 2007.
• Macedonia — an agreement was signed on 8 November 2006 and will enter into force once legislative procedures are completed.
• Poland — the convention takes effect from 1 January 2007 for withholding tax purposes, from 1 April 2007 for corporation tax purposes and from 6 April 2007 for other tax purposes. In Poland, the DTC has effect from 1 January 2007.

HMRC, News Release, 25 July 2007

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