The Double Taxation Dispute Resolution (EU) (Revocation) (EU Exit) Regulations 2020
Published 1 December 2020
© Crown copyright 2020
This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gov.uk.
Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.
This publication is available at https://www.gov.uk/government/publications/the-double-taxation-dispute-resolution-eu-revocation-eu-exit-regulations-2020/the-double-taxation-dispute-resolution-eu-revocation-eu-exit-regulations-2020
The existing Regulations were introduced for the implementation of Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolutions in the European Union (the Directive). The scope of the Directive is limited to member states of the EU. The United Kingdom is no longer a member state of the EU and will cease to be within scope of the Directive following the end of the transition period.
Convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises (90/463/EEC)
It is the shared view of the EU and the UK that on exit day (31 January 2020) the UK ceased to be a party to international agreements in which the UK participated only by virtue of being an EU member state. This includes agreements between the UK and other EU member states entered into in their capacity as EU member states (‘intra-EU agreements’).
However, during the transition period, intra-EU agreements continue to apply in and to the UK. Consequently, the United Kingdom will no longer be covered by the Convention following the end of the transition period.
The United Kingdom will not consider any new requests for access to this Convention submitted to the United Kingdom or a member state of the European Union where the United Kingdom is a party to the dispute after the end of the transition period. The United Kingdom will continue working cases to a conclusion where the requests were received before the end of the transition period.