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The other (D)TT
KEY POINTS
- New double tax treaties will have some fundamental differences from previous ones with Crown dependencies.
- New treaties are consistent with the OECD model convention.
- An ‘offshore activities’ provision is now included.
- The new treaties contain clear residence provisions with tie-breaker provisions.
- In most cases dividends may be paid free of withholding tax in the payer jurisdiction.
- Dual residents will now be able to benefit more readily from treaty relief.
When people think of the Isle of Man (IoM) several things may come to mind: high-speed motor sport; Victorian promenades and long sandy beaches; the Laxey wheel; cyclist Mark Cavendish; or perhaps just cats without tails. However for tax advisers there is often something else – well tax of course.
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