Guidance

Announcement by HMRC of the UK’s tax treaty negotiating priorities for the year to 31 March 2014

Updated 6 January 2015

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This publication is available at https://www.gov.uk/government/publications/announcements-in-2014-of-changes-to-uk-double-taxatation-treaties/announcement-by-hmrc-of-the-uks-tax-treaty-negotiating-priorities-for-the-year-to-31-march-2014

1. Negotiating priorities for the year to 31 March 2014 and report on recent developments

The Government reviews the UK’s Double Taxation Agreement (DTA) and Tax Information Exchange Agreement (TIEA) priorities each year to ensure that the UK’s treaties continue to meet the needs of the businesses and individuals receiving income from abroad. HMRC monitors other countries’ treaties and invites representations from business, individuals, representative bodies, other Government departments and others with an interest in this area. We use the results to produce a programme of work for the year ahead, which is approved by HM Treasury ministers.

2. Programme to 31 March 2014

We plan to begin negotiations on DTAs and Protocols with:

  • Bulgaria
  • Sweden
  • Tajikistan
  • Tanzania

Further announcements may be made as additional negotiations are arranged. We also plan to take forward work on DTAs and Protocols with:

  • Austria
  • Belgium
  • Canada,
  • Croatia
  • Germany
  • Iceland
  • Japan
  • Kosovo
  • Malawi
  • Panama
  • Portugal
  • Russia
  • Senegal
  • Thailand
  • Turkmenistan
  • USA
  • Zambia

We also plan to take forward work on TIEAs with:

  • Andorra
  • Macau
  • Monaco

Negotiations with other countries will be announced when the appropriate opportunity arises.

If you wish to make representations about our forward programme please write to:

Dan Ingreji

HM Revenue & Customs
CT
International, Stamps & Anti-Avoidance (CTISA)

Tax Treaty Team
 Room
3C/03
100 Parliament Street

London 
SW1A 2BQ

E-mail address: dan.ingreji@hmrc.gsi.gov.uk

3. Developments since 1 April 2012

The UK has signed twelve agreements since 1 April 2012.

Dual Taxation Agreements:

  • Albania
  • Barbados
  • Liechtenstein
  • Norway and Spain

DTA Protocols and exchange of letters:

  • Brunei
  • China
  • India
  • Netherlands
  • Switzerland

Tax Information Exchange Agreements:

  • Brazil
  • Marshall Islands.

4. Implementation of agreements

Agreements with the following countries entered into force during the year:

  • Bahrain (DTA)
  • Barbados (DTA)
  • Belgium (Protocol)
  • Ethiopia (DTA)
  • Liberia (TIEA)
  • Liechtenstein (DTA)
  • Singapore (Protocol)
  • South Africa (Protocol - dividends)
  • Switzerland (Exchange of Letters)
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