Bilateral agreement between the United Kingdom and the Netherlands Antilles (Curaçao, Sint Maarten and Bonaire, Sint Eustatius and Saba) on tax cooperation through the exchange of information. It contains stricter provisions for the settlement of the mutual agreement procedure in the event of a double taxation dispute and provides for further adaptations to combat the misuse of transfer pricing to allow tax authorities to adjust transfer prices in order to obtain minimum duration results. Look at tax rates, the latest tax news and information on double taxation agreements with our specialized online resources, guides and useful links. We contain a collection of global double taxation conventions in English (and other languages, if available) to assist members in their applications. If you`re having trouble finding a contract, call the application team on (0)20 7920 8620 or email us at library@icaew.com. On 17 January 2020, HMRC announced that the TREATY protocol between the United Kingdom and Ukraine, signed on 9 October 2017, came into force on 5 December 2019. The protocol introduces several changes, including a 5 per cent withholding tax on interest instead of the previous 10 per cent rate, a TPP and the mutual agreement procedure for arbitration. The provisions of the protocol apply from 1 January 2020 for withholding taxes, 6 April 2020 for UK income and capital gains tax and 1 April 2020 for UK corporate tax. The new DTT no longer contains such a residence arrangement. Rather, it provides that when a company is domiciled in both the United Kingdom and the Netherlands, the competent authorities must agree on the residence by mutual agreement and not on the basis of determining the place of effective administration.

If there is no mutual agreement, the company is deemed not to reside in any of the parties and is therefore not entitled to the benefits of the new DTT, with the exception of the terms of double taxation, non-discrimination and mutual agreement of the new DTT. The treaty amendments are intended to combat hybrid interest agreements, which can lead to double non-taxation or double deductions for the same income and contract abuse. In addition, provisions are added to prevent non-application of settlement rules, and they are also intended to improve dispute resolution. The new DTT contains specific provisions that generally aim to avoid double taxation and non-taxation of so-called “transparent” entities. On 6 and 10 January 2020, HMRC published summary texts of the UK double taxation agreements with the Netherlands and Belgium, which reflect the changes made by the MLI to the respective contracts. The documents come from the legal orders that file with the OECD the instrument of ratification of the LMM and reflect the changes and reservations of each country that were submitted to the custodian at the time of ratification. On 6 January 2020, the UK Government published the summarised text of the 2008 Double Taxation Convention concluded by the Netherlands and the United Kingdom, as amended by the multilateral instrument BEPS. Residents and most non-residents are entitled to the exemption from double taxation through unilateral discharge provisions or tax treaties. We have had a start of work in 2020 in the area of UK tax policy, which includes significant and positive developments in the UK`s network of double taxation conventions. 2019 ended with the conclusion by the United Kingdom of an agreement on double taxation with Colombia, the entry into force of the Israeli Treaty and the publication of the summary texts of the Multilateral Convention on the Implementation of Measures related to the Tax Convention to Prevent Erosion and Profit Transfer – the Multilateral Instrument (MLI) – with important jurisdictions, including Canada, India and Luxembourg.